Energy Conservation Program: Test Procedures for Residential Clothes Washers
Federal RegisterMar 7, 2012
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DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[Docket No. EERE-2010-BT-TP-0021]
RIN 1904-AC08
Energy Conservation Program: Test Procedures for Residential Clothes Washers
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Final rule.
SUMMARY:
The U.S. Department of Energy (DOE) establishes new test procedures for residential clothes washers under the Energy Policy and Conservation Act. The new test procedures include provisions for measuring standby mode and off mode energy consumption, and update the provisions for measuring active mode energy and water consumption. This final rule also amends the certification, compliance, and enforcement requirements for residential clothes washers, amends provisions for calculating the estimated annual operating cost for clothes washers, eliminates an obsolete clothes washer test procedure, and amends certain provisions in the currently applicable test procedure.
DATES:
This final rule is effective April 6, 2012. Manufacturers will be required to certify compliance using the appendix J2 test procedure beginning on the compliance date of any final rule establishing amended energy conservation standards that address standby and off mode power for residential clothes washers. Before that time, manufacturers may continue to certify compliance using the test procedure at appendix J1.
The incorporation by reference of certain publications listed in this rulemaking is approved by the Director of the Office of the Federal Register as of April 6, 2012.
ADDRESSES:
The docket is available for review at
http://www.regulations.gov
, including
Federal Register
notices, framework documents, public meeting attendee lists and transcripts, comments, and other supporting documents/materials. All documents in the docket are listed in the regulations.gov index. However, not all documents listed in the index may be publicly available, such as information that is exempt from public disclosure. A link to the docket Web page can be found at:
www.regulations.gov/#!docketDetail;D=EERE-2010-BT-TP-0021
. The
regulations.gov
Web page contains instructions on how to access all documents, including public comments, in the docket.
For further information on how to review the docket, contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov
.
FOR FURTHER INFORMATION CONTACT:
Mr. Stephen L. Witkowski, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 586-7463. Email:
Stephen.Witkowski@ee.doe.gov
.
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of the General Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 586-7796. Email:
Elizabeth.Kohl@hq.doe.gov
.
SUPPLEMENTARY INFORMATION:
This final rule incorporates by reference into part 430 the following industry test standards:
(1) AATCC Test Method 79-2010, Absorbency of Textiles, Revised 2010.
(2) AATCC Test Method 118-2007, Oil Repellency: Hydrocarbon Resistance Test, Revised 2007.
(3) AATCC Test Method 135-2010, Dimensional Changes of Fabrics After Home Laundering, Revised 2010.
(4) IEC Standard 62301, Household Electrical Appliances—Measurement of Standby Power, Edition 2.0, 2011-01.
Copies of AATCC standards can be obtained from the American Association of Textile Chemists and Colorists, P.O. Box 12215, Research Triangle Park, NC 27709, (919) 549-3526, or
www.aatcc.org
.
Copies of IEC standards can be obtained from the American National Standards Institute, 25 W. 43rd Street, 4th Floor, New York, NY 10036, (212) 642-4900, or
http://webstore.ansi.org/
.
Table of Contents
I. Authority and Background
A. General Test Procedure Rulemaking Process
B. DOE Test Procedure at Appendix J1
C. Clothes Washer Test Procedure Updates: Authority and Regulatory Background
II. Summary of the Final Rule
A. Standby and Off Mode
B. Water Consumption
C. Updated Consumer Usage Patterns
D. Energy Test Cycle Definition
E. Capacity Measurement Method
F. Test Cloth, Detergent, and Preconditioning Test Equipment
G. Testing Conditions
H. Clarifications and Corrections
I. Annual Operating Cost Calculation
J. Revisions to Appendix J1
K. Removal of Appendix J
L. Certification, Compliance, and Enforcement Requirements
III. Discussion
A. Products Covered by This Test Procedure Final Rule
B. Standby Mode and Off Mode Test Procedure Provisions
1. Version of IEC Standard 62301
2. Determination of Modes To Be Incorporated
a. Active Mode
b. Delay Start Mode
c. Cycle Finished Mode
d. Self-Clean Mode
e. Standby Mode
f. Off Mode
g. Network Mode
h. Disconnected Mode
3. Power Stabilization Criteria and Measurement Methods
a. Stable, Non-Cyclic Power
b. Unstable (Varying), Non-Cyclic Power
c. Cyclic Power
4. Use of Default Settings
5. Test Room Ambient Temperature Conditions for Standby Power Testing
6. Power Supply and Power Measuring Instruments
7. Calculation of Energy Consumption in Each Mode
8. Integrated Modified Energy Factor (IMEF)
C. Active Mode Test Procedure Provisions
1. Integrated Water Consumption Factor (IWF)
2. Technologies Not Covered by the Current Test Procedure
a. Steam Wash Cycles
b. Self-Clean Cycles
c. Adaptive Control Technologies
d. Demand Response Technologies
3. Consumer Usage Patterns
a. Number of Annual Wash Cycles
b. Test Load Size Specifications
c. Load Usage Factors
d. Temperature Use Factors
e. Dryer Usage Factor
f. Load Adjustment Factor
4. Energy Test Cycle Definition
a. Part (A) of the Proposed Definition
b. Part (B) of the Proposed Definition
c. Part (C) of the Proposed Definition
d. Part (D) and Part (E) of the Proposed Definition
e. New Section 2.13
f. Reporting Requirements
5. Capacity Measurement Method
6. Test Cloth, Detergent, and Preconditioning Test Equipment
a. Test Cloth Definitions
b. Energy Test Cloth Size and Weight Tolerances
c. Detergent Specification and Dosage
d. Test Cloth Preconditioning Wash Requirements
e. AATCC Test Methods
f. Required Extractor Tests
g. Extractor Specification
h. Bone Dryer Specifications
i. Procedures for Preparing and Handling Test Cloth Bundles
j. Clarification of the RMC Nomenclature and Application of the RMC Correction Curve
k. Removal of Redundant Sections
7. Testing Conditions
a. Water Supply Pressure
b. Water Inlet and Drain Hoses
8. Clarifications and Corrections
a. Correction of Cold Rinse Definition
b. Clarification of Wash Time Setting for Electromechanical Dials
c. Clarification of Cold Wash Definition
d. Removal of Obsolete Note in Water Factor Calculation Section
e. Correction of Typographical Error in Hot Water Consumption Calculation
f. Removal of Energy Factor Calculation
g. Clarification of Waiver Field Test Equation
h. Clarification of Water Factor Terminology
9. Test Procedure Performance Specifications
D. Annual Operating Cost Calculation
E. Revisions to Appendix J1
1. Revision of Introductory Text
2. Correction of Typographical Errors in Materials Incorporated by Reference
3. Correction of Cold Rinse Definition
4. Removal of Redundant Sections
5. Detergent Specification and Dosage
6. Wash Time Setting for Electromechanical Dials
7. Clarification of Cold Wash Definition
8. Removal of Obsolete Note in Water Factor Calculation Section
9. Clarification of Water Factor Terminology
10. Correction of Typographical Error in Hot Water Consumption Calculation
11. Extension of Test Load Size Table
12. Clarification of Waiver Field Test Equation
13. Corrections to Provisions for Calculating the RMC Correction Curve
F. Removal of Obsolete Test Procedure at Appendix J
G. Compliance With Other EPCA Requirements
1. Test Burden
2. Integration of Standby Mode and Off Mode Energy Consumption Into the Energy Efficiency Metrics
3. Impacts on Commercial Clothes Washers
4. Certification, Compliance, and Enforcement Requirements
H. Impacts of the Test Procedure Amendments on EnergyGuide and ENERGYSTAR
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
B. Review Under the Regulatory Flexibility Act
C. Review Under the Paperwork Reduction Act of 1995
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under Treasury and General Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under Section 32 of the Federal Energy Administration Act of 1974
M. Congressional Notification
N. Approval of the Office of the Secretary
I. Authority and Background
Title III of the Energy Policy and Conservation Act (42 U.S.C. 6291,
et seq.;
“EPCA”) sets forth a variety of provisions designed to improve energy efficiency. (All references to EPCA refer to the statute as amended through the Energy Independence and Security Act of 2007 (EISA 2007), Public Law 110-140 (Dec. 19, 2007)). Part B of title III, which for editorial reasons was redesignated as Part A upon incorporation into the U.S. Code (42 U.S.C. 6291-6309), establishes the “Energy Conservation Program for Consumer Products Other Than Automobiles.” These include residential clothes washers, the subject of this final rule. (42 U.S.C. 6292(a)(7))
Under EPCA, this program consists essentially of four parts: (1) Testing, (2) labeling, (3) Federal energy conservation standards, and (4) certification and enforcement procedures. The testing requirements consist of test procedures that manufacturers of covered products must use as the basis for certifying to DOE that their products comply with the applicable energy conservation standards adopted under EPCA, and for making representations about the efficiency of those products. Similarly, DOE must use these test requirements to determine whether the products comply with any relevant standards promulgated under EPCA.
A. General Test Procedure Rulemaking Process
Under 42 U.S.C. 6293, EPCA sets forth the criteria and procedures DOE must follow when prescribing or amending test procedures for covered products. EPCA provides that any test procedures prescribed or amended under this section shall be reasonably designed to produce test results which measure energy efficiency, energy use or estimated annual operating cost of a covered product during a representative average use cycle or period of use and shall not be unduly burdensome to conduct. (42 U.S.C. 6293(b)(3)) If DOE determines that a test procedure amendment is warranted, it must publish proposed test procedures and offer the public an opportunity to present oral and written comments on them. (42 U.S.C. 6293(b)(2))
DOE is codifying these changes to the clothes washer test procedure as a new appendix J2 in 10 CFR part 430 subpart B. Manufacturers will not be required to use appendix J2 to demonstrate compliance with clothes washer energy conservation standards until the compliance date of amended energy conservation standards that consider the methods and measurements included in the new test procedure. Until that time, manufacturers may continue to use appendix J1.
EPCA requires DOE to review its test procedures at least once every seven years to determine whether amendments are warranted. (42 U.S.C. 6293(b)(1)) This rulemaking satisfies EPCA's periodic review requirement. Table I.1 provides a summary of prior key regulatory and legislative actions regarding the residential clothes washer test procedure and energy conservation standards, which are relevant to this final rule. The first column contains the abbreviated names used in this preamble to refer to each action.
Table I.1—Summary of Relevant Regulatory and Legislative Actions for Residential Clothes Washers
Name
Action
Citation and date
Summary of action
TEST PROCEDURES
August 1997 Final Rule
Final Rule
62 FR 45484 (August 27, 1997)
Established new test procedure at appendix J1.
September 2010 NOPR
Notice of Proposed Rulemaking
75 FR 57556 (September 21, 2010)
Proposed new appendix J2 to incorporate standby and off mode and to amend certain active mode provisions; proposed changes to appendix J1; proposed removal of appendix J.
October 2010 public meeting
Public meeting
October 28, 2010
Public meeting to discuss proposed test procedure amendments.
August 2011 SNOPR
Supplementary Notice of Proposed Rulemaking
76 FR 49238 (August 9, 2011)
Proposed revisions to new appendix J2 to incorporate provisions of IEC Standard 62301 (2nd Ed.); proposed minor amendments to appendix J1.
November 2011 SNOPR
Supplementary Notice of Proposed Rulemaking
76 FR 69870 (November 9, 2011)
Proposed amended definition of the energy test cycle for the proposed new appendix J2.
ENERGY CONSERVATION STANDARDS
January 2001 standards Final Rule
Final Rule
66 FR 3314 (January 12, 2001)
Required use of appendix J1 to demonstrate compliance with amended energy conservation standards as of January 1, 2004; amended test procedure provisions related to remaining moisture content and test cloth.
August 2009 standards framework document
Framework document
74 FR 44306 (August 28, 2009)
Developed to consider amended energy conservation standards.
September 2009 standards public meeting
Public meeting
September 21, 2009
Public meeting to discuss energy conservation standards rulemaking; included test procedure issues.
LEGISLATION
EPCA
Legislation
Energy Policy and Conservation Act, Pub. L. 94-163
Established authority for energy conservation standards and test procedures.
EISA 2007
Legislation
Energy Independence and Security Act of 2007, Pub. L. 110-140
Required standby and off mode energy to be integrated into overall energy descriptors for residential clothes washers, if technically feasible.
B. DOE Test Procedure at Appendix J1
The DOE test procedure for clothes washers currently being manufactured is found at 10 CFR part 430, subpart B, appendix J1, which was adopted by DOE in the August 1997 Final Rule. DOE added the new appendix J1 so that appendix J could still be used until DOE amended the residential clothes washer conservation standards
1
, which DOE published in the January 2001 standards Final Rule. Until the compliance date of any amended standards for residential clothes washers, manufacturers may continue to use the appendix J1 test procedure to demonstrate compliance with current energy conservation standards.
1
Because appendix J applies only to clothes washers manufactured before January 1, 2004, appendix J is now obsolete.
The test procedure at appendix J1 includes provisions for determining the modified energy factor (MEF) and water factor (WF). The test procedure at appendix J1 does not address energy use in standby or off modes.
C. Clothes Washer Test Procedure Updates: Authority and Regulatory Background
EISA 2007 amended EPCA to require DOE to amend its test procedures for all covered products to integrate measures of standby mode and off mode energy consumption into the overall energy efficiency, energy consumption, or other energy descriptor, unless the current test procedure already incorporates standby and off mode energy consumption, or if such integration is technically infeasible. If an integrated test procedure is technically infeasible, DOE must prescribe a separate standby mode and off mode energy use test procedure for the covered product, if a separate test is technically feasible. (42 U.S.C. 6295(gg)(2)(A)) Any such amendment must consider the most current versions of International Electrotechnical Commission (IEC) Standard 62301, “Household electrical appliances—Measurement of standby power” (“IEC Standard 62301 (Second Edition)” or “Second Edition”) and IEC Standard 62087, “Methods of measurement for the power consumption of audio, video, and related equipment.”
2
Amendments to test procedures to include standby and off mode energy consumption are not used to determine compliance with previously-established standards. (42 U.S.C. 6295(gg)(2)(C))
2
IEC standards are available online at
www.iec.ch
.
DOE is considering amending standards for clothes washers in a separate rulemaking, including amendments to the water consumption standards established in EISA 2007.
3
(42 U.S.C. 9295(g)(9) In the August 2009 standards framework document, available at
http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/clothes_washers_framework.pdf
, DOE requested comments on revising the clothes washer test procedure. Issues presented in the framework document, including issues related to the test procedure, were discussed at the September 2009 standards public meeting.
3
EISA 2007 amended EPCA, in relevant part, to revise the energy conservation standards for residential clothes washers. The revised standards established a maximum water consumption factor (WF) of 9.5, effective January 1, 2011.
In response to the August 2009 standards framework document, DOE received comments stating that it should consider changes to the active mode test procedure for clothes washers. As a result, DOE proposed in the September 2010 NOPR to address issues regarding the active mode provisions of the test procedure, in addition to proposing the inclusion of measures for standby and off mode power. The proposals are discussed in greater detail below.
DOE proposed a number of revisions and additions to the test procedure in the September 2010 NOPR, including: (1) Incorporating standby and off mode power into a combined energy metric; (2) addressing technologies not covered by the appendix J1 test procedure, such as steam wash cycles and self-clean cycles; (3) revising the number of annual wash cycles; (4) updating use factors; (5) revising the procedures and specifications for test cloth; (6) redefining the appropriate water fill level for the capacity measurement method; (7) establishing a new measure of water consumption; and (8) revising the definition of the energy test cycle. DOE requested comment on the proposals in the September 2010 NOPR and discussed the proposals at the October 2010 public meeting.
The August 2011 SNOPR proposed to incorporate certain provisions of IEC Standard 62301 (Second Edition), as well as additional amendments addressing the following: (1) The energy test cycle definition; (2) the load adjustment factor; (3) the wash time setting for certain clothes washers; (4) the calculation of annual energy cost; (5) extension of the test load size table; (6) the definition of cold rinse; (7) redundant sections for test cloth specifications; (8) the detergent specification; (9) the definition of cold wash; and (10) the calculations for per-cycle self-clean water consumption. DOE requested comment on the proposals in the August 2011 SNOPR.
The November 2011 SNOPR proposed a revised definition for the energy test cycle. DOE requested additional comment on its proposal.
In today's final rule, DOE addresses comments it received on the September 2010 NOPR that were not previously addressed in the August 2011 SNOPR, as well as comments received in response to the August 2011 SNOPR and November 2011 SNOPR. DOE responds to these comments in section III.
II. Summary of the Final Rule
In this final rule, DOE establishes a new clothes washer test procedure (in a new appendix J2) that integrates measures of standby mode and off mode energy consumption, as well as measures of energy consumption in certain additional modes determined to be part of active mode. This final rule also: (1) Introduces a new efficiency metric for water consumption; (2) more accurately reflects current consumer usage patterns; (3) revises the energy test cycle definition; (4) revises the capacity measurement method; (5) addresses issues related to the test cloth, including the preconditioning detergent and test equipment; (6) clarifies certain testing conditions; (7) provides additional clarifications and corrections to certain provisions of the test procedure; (8) revises the calculation for annual operating cost; (9) revises and clarifies certain provisions in appendix J1; (10) removes the obsolete appendix J to subpart B of 10 CFR part 430; and (11) amends the certification, compliance, and enforcement requirements for residential clothes washers. The following paragraphs summarize these changes.
A. Standby and Off Mode
The new clothes washer test procedure includes provisions for measuring energy consumption in standby and off modes. DOE incorporates by reference IEC Standard 62301 (Second Edition). In the new test procedure, DOE includes language to clarify the application of clauses from the Second Edition regarding test conditions and test procedures for measuring standby mode and off mode energy consumption. The new test procedure includes definitions of “active mode,” “standby mode,” and “off mode” based on the definitions provided in the Second Edition. It also incorporates a simplified measurement approach that accounts for energy consumption in all low-power modes—including standby, off, delay start, and cycle finished modes—by means of a single power measurement. DOE also adopts a new measure of energy efficiency, the integrated modified energy factor (IMEF), which includes the energy used in the active, standby, and off modes.
B. Water Consumption
The new test procedure establishes a new measure of efficiency, the integrated water consumption factor (IWF), which incorporates the water consumption of all wash/rinse test cycles.
C. Updated Consumer Usage Patterns
The new test procedure updates certain values from the existing test procedure to reflect current consumer usage patterns and capabilities. This final rule: (1) Updates the number of annual wash cycles and incorporates it into the calculation for combined low-power mode energy consumption; (2) extends the test load sizes table to accommodate test loads for large-capacity clothes washers; (3) updates the temperature use factors for the warm/cold and warm/warm temperature combinations to accommodate the warm/warm cycle as a complete cycle; (4) updates the dryer usage factor; and (5) replaces the current representative load size calculation in the drying energy equation, which is based on the load adjustment factor, with a weighted-average load size based on the minimum, average, and maximum load sizes and the load usage factors.
D. Energy Test Cycle Definition
The new test procedure modifies the definition of the energy test cycle to improve clarity, which DOE believes will result in more accurate, repeatable, and reproducible results within and among all test laboratories.
E. Capacity Measurement Method
The new test procedure modifies the capacity measurement method to improve clarity, repeatability, and reproducibility, and to more appropriately represent the usable volume of the clothes washer during operation.
F. Test Cloth, Detergent, and Preconditioning Test Equipment
The new test procedure: (1) Includes new test cloth definitions; (2) establishes tolerances for the size and weight of the test cloth; (3) updates the detergent specification to reflect the current industry-standard detergent; (4) updates the test cloth preconditioning wash requirements; (5) updates the industry test methods referenced in the test procedure to reflect the current versions of each standard; (6) adds a new industry test method for measuring test cloth shrinkage; (7) adds a requirement to conduct extractor tests at the 650 g-force level; (8) updates the extractor specification; (9) adds specifications for the dryer to be used for bone-drying the test cloth; (10) clarifies the procedures for preparing and handling test cloth bundles; (11) clarifies the remaining moisture content (RMC) nomenclature used throughout the test procedure; (12) clarifies the application of the RMC correction curve; and (13) removes redundant sections regarding test cloth specifications and preconditioning, which were made obsolete by the January 2001 standards Final Rule.
G. Testing Conditions
Today's final rule clarifies the water supply pressure specification.
H. Clarifications and Corrections
This final rule: (1) Corrects the definition of “cold rinse”; (2) clarifies the method for setting the wash time on clothes washers with electromechanical dials; (3) clarifies the definition of “cold wash” for clothes washers that offer multiple cold wash settings; (4) removes an obsolete note in the water factor calculation section; (5) corrects a typographical error in the equation for calculating per-cycle hot water consumption using gas-heated or oil-heated water; (6) removes the obsolete calculation of energy factor (EF); (7) clarifies the procedures recommended for conducting field tests in support of a test procedure waiver; (8) clarifies the water factor metric terminology; and (9) corrects typographical errors in materials incorporated by reference.
I. Annual Operating Cost Calculation
Today's final rule amends the annual operating cost calculation in 10 CFR 430.23(j) to incorporate the cost of energy consumed in standby and off
modes, and to reflect an updated number of annual use cycles.
J. Revisions to Appendix J1
This final rule revises and clarifies certain provisions in appendix J1, some of which are identical to revisions made in appendix J2. Manufacturers will continue to use the amended version of appendix J1 to certify compliance until use of appendix J2 is required for certification.
Specifically, this final rule: (1) Revises the introductory text to appendix J1; (2) corrects typographical errors in materials incorporated by reference; (3) corrects the definition of “cold rinse”; (4) removes redundant sections regarding test cloth specifications and preconditioning, which were made obsolete by the January 2001 standards Final Rule; (5) updates the test cloth preconditioning detergent specification to reflect the current industry-standard detergent; (6) clarifies the method for setting the wash time for clothes washers with electromechanical dials; (7) clarifies the definition of “cold wash” for clothes washers that offer multiple cold wash settings; (8) removes an obsolete note in the water factor calculation section; (9) corrects a typographical error in the equation for calculating per-cycle hot water consumption using gas-heated or oil-heated water; (10) extends the load size table to accommodate test loads for large-capacity clothes washers; (11) clarifies the procedures recommended for conducting field tests in support of a test procedure waiver; and (12) corrects and clarifies provisions for calculating the RMC correction curve.
K. Removal of Appendix J
Today's final rule removes appendix J to subpart B of 10 CFR part 430, which became obsolete when appendix J1 became effective.
L. Certification, Compliance, and Enforcement Requirements
Today's final rule modifies the reporting requirements in 10 CFR 429.20(b)(2) by specifying that a certification report shall include publicly available information including MEF, WF, and capacity; as well the list of cycle settings comprising the complete energy test cycle for each basic model, which would not be made publicly available as part of the report. The requirement to provide the list of cycle settings comprising the complete energy test cycle will apply only to test results obtained using appendix J2.
III. Discussion
A. Products Covered by This Test Procedure Final Rule
Today's final rule covers residential clothes washers, defined as follows in 10 CFR 430.2:
Clothes washer
means a consumer product designed to clean clothes, utilizing a water solution of soap and/or detergent and mechanical agitation or other movement, and must be one of the following classes: Automatic clothes washers, semi-automatic clothes washers, and other clothes washers.
Automatic clothes washer
means a class of clothes washer which has a control system which is capable of scheduling a preselected combination of operations, such as regulation of water temperature, regulation of the water fill level, and performance of wash, rinse, drain, and spin functions without the need for user intervention subsequent to the initiation of machine operation. Some models may require user intervention to initiate these different segments of the cycle after the machine has begun operation, but they do not require the user to intervene to regulate the water temperature by adjusting the external water faucet valves.
Semi-automatic clothes washer
means a class of clothes washer that is the same as an automatic clothes washer except that user intervention is required to regulate the water temperature by adjusting the external water faucet valves.
Other clothes washer
means a class of clothes washer which is not an automatic or semi-automatic clothes washer.
Pursuant to 42 U.S.C. 6295(q), existing energy conservation standards divide residential clothes washers into five product classes (10 CFR 430.32(g)):
• Top-loading, Compact (less than 1.6 cubic feet capacity)
• Top-loading, Standard (1.6 cubic feet or greater capacity)
• Top-loading, Semiautomatic
• Front-loading
• Suds-saving
DOE received comments from interested parties regarding clothes washer product classes in response to the September 2010 NOPR. BSH Home Appliances (BSH) commented that it supports removing the distinction between front-loading and top-loading clothes washers. DOE notes that the amended test procedure contains provisions for testing both top-loading and front-loading clothes washers of varying capacities. DOE is considering the issue of how clothes washers should be grouped into product classes in the separate rulemaking addressing energy conservation standards for residential clothes washers (Docket EERE-2008-BT-STD-0019).
The People's Republic of China (China) commented that DOE did not specifically consider non-detergent types of clothes washers, and that DOE should set appropriate energy efficiency requirements for such non-detergent machines. (China, No. 19 at p. 4) DOE does not have any information on residential clothes washers currently available in the United States that use cleaning mechanisms other than the combination of water, detergent, and mechanical agitation. Therefore, DOE is not incorporating any changes to the definitions of covered products in today's final rule.
B. Standby Mode and Off Mode Test Procedure Provisions
This section describes the standby and off mode test procedure provisions adopted in today's final rule. DOE received a number of comments from interested parties regarding the standby and off mode definitions and test procedure provisions in IEC Standard 62301 proposed in the September 2010 NOPR. DOE responded to many of these comments in the August 2011 SNOPR and addresses additional comments from the September 2010 NOPR and the August 2011 SNOPR in the discussion that follows.
1. Version of IEC Standard 62301
DOE proposed in the September 2010 NOPR to incorporate by reference certain provisions from sections 4 and 5 of IEC Standard 62301 (First Edition), as well as certain provisions from the Committee Draft for Vote (CDV) version and the Final Draft International Standard (FDIS) version, developed prior to the issuance of the Second Edition. DOE received numerous comments in response to the September 2010 NOPR regarding the version of IEC Standard 62301, and provided responses to comments in the August 2011 SNOPR.
Based on comments from interested parties, DOE proposed in the August 2011 SNOPR to incorporate by reference the Second Edition of IEC Standard 62301 for measuring standby and off mode power. Specifically, DOE proposed referencing the following sections in the Second Edition: (1) The room ambient air conditions specified in section 4, paragraph 4.2; (2) the electrical supply voltage waveform specified in section 4, paragraph 4.3.2; (3) the power meter requirements specified in section 4, paragraph 4.4; (4) the note regarding the time required to
enter a stable power state in section 5, paragraph 5.1, note 1; (5) the installation instructions in section 5, paragraph 5.2; and (6) the power sampling method specified in section 5, paragraph 5.3.2.
DOE received the following comments in response to the August 2011 SNOPR: The Association of Home Appliance Manufacturers (AHAM), Alliance Laundry Systems (ALS), the Northwest Energy Efficiency Alliance (NEEA), and Whirlpool Corporation (Whirlpool) reiterated their support for incorporating by reference the Second Edition of IEC Standard 62301. AHAM and ALS stated that the Second Edition contains a number of important clarifications not present in the First Edition. Furthermore, AHAM and ALS stated that adopting the Second Edition will allow for international harmonization, which will give clarity and consistency to the regulated community. AHAM also stated that the Second Edition decreases testing burden. Whirlpool stated that the incorporation of the Second Edition should not be applicable until the effective date of appendix J2. (AHAM, No. 24 at p. 2; ALS, No. 22 at p. 1; NEEA, No. 26 at p. 2; Whirlpool, No. 27 at p. 1)
In this final rule, DOE incorporates by reference IEC Standard 62301 (Second Edition) for the test procedure in appendix J2. DOE believes that the new test procedures provide improved accuracy and representativeness of the resulting power measurement, and are not unduly burdensome to conduct, as described further in sections III.B.6 and III.G.1.
This final rule also amends 10 CFR 430.3 by adding a reference to IEC Standard 62301 (Second Edition). DOE retains the reference to the First Edition in 10 CFR 430.3 because several test procedures for other covered products not addressed in this final rule incorporate provisions from the First Edition.
Today's final rule also corrects the address and telephone number listed for the American National Standards Institute (ANSI) under the newly designated section for IEC standards in 10 CFR 430.3(m). The current address and phone number for ANSI is 25 W. 43rd Street, 4th Floor, New York, NY 10036, (212) 642-4900. This correction is consistent with the address and phone number currently listed for ANSI in 10 CFR 430.3(c).
2. Determination of Modes To Be Incorporated
EPCA provides mode definitions for active mode, standby mode, and off mode, but authorizes DOE to amend these mode definitions by taking into consideration the most current version of IEC Standard 62301. (42 U.S.C. 6295(gg)(1)(B)) In the September 2010 NOPR, DOE noted that the mode definitions provided in IEC Standard 62301 (First Edition) and EPCA (as amended by EISA 2007) were designed to be broadly applicable for many energy-using products and could be subject to multiple interpretations. Therefore, DOE proposed mode definitions based on those provided in IEC Standard 62301 (FDIS), but with added clarifications specific to clothes washers.
In response to the September 2010 NOPR, NEEA commented that DOE's proposed modes and definitions would systematically exclude significant potential sources of annual energy use in many clothes washers. (NEEA, No. 12 at p. 2) NEEA also commented that DOE did not incorporate the “Definitions” section of IEC Standard 62301, and expressed concern about possible discrepancies between the modes specified in IEC Standard 62301 and the modes that are defined in EPCA. (NEEA, Public Meeting Transcript, No. 20 at pp. 22-23) NEEA added that not defining the modes identically with the IEC definitions could create inconsistencies in the way the modes are measured. (NEEA, Public Meeting Transcript, No. 20 at p. 24) NEEA's comments regarding specific modes and definitions are addressed in the relevant sections that follow.
For the reasons stated above, DOE maintained the mode definitions proposed in the September 2010 NOPR in the August 2011 SNOPR. DOE further proposed an “alternate approach” for measuring total energy consumption. In the alternate approach, the energy consumption of all low-power modes would be measured only in the inactive and off modes, and all low-power mode hours would be allocated to the inactive and off modes, depending on which of these modes is present.
In response to the August 2011 SNOPR, AHAM agreed that the Second Edition definitions are identical to those in the FDIS version and, thus, do not need to be revised. AHAM added that if DOE chooses to reference IEC Standard 62301 for those definitions, it should reference the Second Edition, not the FDIS, because the Second Edition is the final, published, and most current version of the standard. (AHAM, No. 24 at pp. 2-3)
DOE also proposed in the August 2011 SNOPR that certain installation instructions in IEC Standard 62301 (Second Edition) regarding the determination, classification, and testing of relevant modes were not appropriate for the clothes washer test procedure. Section 5, paragraph 5.2 of the Second Edition requires that where instructions for use provide configuration options, each relevant option should be separately tested. As stated in the August 2011 SNOPR, DOE is concerned that this requirement to separately test each configuration option could substantially increase test burden. It also potentially conflicts with the requirement in paragraph 5.2 to set up the product in accordance with the instructions for use or, if no such instructions are available, to use the factory or default settings. Accordingly, DOE proposed qualifying language in the test procedure amendments to disregard those portions of the installation instructions. For these reasons, DOE adopts language in today's final rule to disregard the provisions of paragraph 5.2 regarding the determination, classification, and testing of relevant modes.
The sections below provide additional details regarding the definition and inclusion of each specific mode within the revised test procedure.
Active Mode
DOE proposed in the September 2010 NOPR to define active mode as a mode in which the clothes washer is connected to a main power source; has been activated; and is performing one or more of the main functions of washing, soaking, tumbling, agitating, rinsing, and/or removing water from the clothing, or is involved in functions necessary for these main functions, such as admitting water into the washer or pumping water out of the washer. DOE also proposed including three additional modes within active mode: Delay start mode, cycle finished mode, and self-clean mode.
AHAM and the Pacific Gas and Electric Company (PG&E), Southern California Gas Company (SCG), San Diego Gas and Electric (SDG&E), and Southern California Edison (SCE) (collectively, the “California Utilities”) support the active mode definition proposed in the September 2010 NOPR, which would include delay start, cycle finished, and self-clean modes. (AHAM, No. 14 at p. 4; California Utilities, No 18 at p. 2) However, AHAM stated that it opposes DOE's proposal to measure the energy use in delay start and cycle finished modes separately from the energy use of the active washing mode because delay start and cycle finished modes represent a very small contribution to the annual energy use. (AHAM, No. 14 at pp. 3-4) The California Utilities expressed concern
about how the power in these modes is measured and included in the proposed test procedure. (California Utilities, No 18 at p. 2)
NEEA agreed with the proposal to define delay start and cycle finished modes as active modes, but commented that the point at which the active washing mode ends and the inactive mode begins is not clear. NEEA recommended that DOE define the end of the active washing mode so that manufacturers will know when to stop the energy measurement. (NEEA, Public Meeting Transcript, No. 20 at p. 97; NEEA, No. 12 at pp. 2, 4, 5; NEEA, No. 26 at pp. 2, 4-5) NEEA further commented that the spin cycle is typically the last element of an active wash mode, and access to the clothes washing compartment is prevented until this part of the cycle has concluded; thus, the point at which the user can gain access to the wash compartment is one possible definition for the end of the active washing mode. (NEEA, No. 12 at p. 7; NEEA, No. 26 at p. 6)
NEEA also suggested that active mode could be defined as starting with the activation of the delayed start mode, if any (with the duration of delayed start mode specified), and ending with the beginning of the inactive mode (with the duration of the cycle finished mode, if any, specified, either in minutes or number of cycles or both). (NEEA, No. 12 at p. 4-5) NEEA expressed concern that the definition of the active washing mode leaves out functions that might occur in delay start, cycle finished, or self-clean modes. (NEEA, No. 12 at p. 4) NEEA further suggested that if delay start and cycle finished modes are defined as part of the active mode, DOE could include them in the definition of the active mode energy test cycle and specify their durations. NEEA noted that while this would lengthen the test cycle, it would probably result in an overall reduction in test procedure time by eliminating the setup time and separate measurement time required for measuring energy consumption in these two modes. (NEEA, No. 12 at p. 13-14)
The Natural Resources Defense Council (NRDC) questioned whether the active washing mode includes the pre- and post-parts of the active cycle. (NRDC, Public Meeting Transcript, No. 20 at pp. 96-97)
DOE notes that the adopted definition of active washing mode includes the main function of removing water from the clothing;
i.e.,
the final spin cycle, which is typically the last operation of a wash cycle. DOE infers from NEEA's comments that its concern about defining the end of active washing mode relates to clothes washers in which there may be additional energy-consuming functions other than a continuous status display in cycle finished mode, such as periodic tumbling or air circulation. As discussed in section III.B.2.c, this final rule does not require the testing of any cycle-finished activity. Thus, for the purpose of measuring energy consumption in the energy test cycle, the end of the active washing mode occurs at the end of the final spin to remove moisture.
This final rule also accounts for the energy use of delay start mode by allocating the hours not associated with active washing mode (which include those associated with delay start mode) to the inactive and off modes, as described in section III.B.7. The energy use of delay start mode is therefore not separately measured, as discussed in section III.B.2.b.
Delay Start Mode
In the September 2010 NOPR, DOE proposed to define delay start mode as an active mode in which the start of the active washing mode is facilitated by a timer. Because delay start mode is not a mode that may persist for an indefinite time, and is uniquely associated with the initiation of a main function (
i.e.,
washing cycle), DOE determined that it would not be considered as part of standby mode.
4
For this final rule, DOE has determined that because delay start is of limited duration and is uniquely associated with the initiation of a primary function, it should be considered part of active mode.
4
DOE noted in the September 2010 NOPR that section 3.8 of IEC Standard 62301 Committee Draft 2 (IEC Standard 62301 CD2) provided the additional clarification that “delay start mode is a one-off user-initiated short-duration function that is associated with an active mode.” The subsequent IEC Standard 62301 CDV removed this clarification based on a comment from a committee member that the clarification conflicted with the proposed definition of “standby mode,” which would include “activation of * * * active mode by * * * timer.” In its response to that comment, however, the IEC reiterated that delay start mode is a one-off function of limited duration, even though it took action to delete the clarification in IEC Standard 62301 CDV. DOE inferred this to mean that that delay start mode should, therefore, be considered part of active mode. DOE also notes that Annex A of IEC Standard 62301 (Second Edition) classifies delay start as a secondary function and therefore not part of active mode.
DOE proposed in the September 2010 NOPR to measure delay start mode by setting the delay start time to 5 hours, allowing at least a 5-minute stabilization period, and then measuring and recording the average power over a 60-minute measurement period.
In the August 2011 SNOPR, DOE proposed not to adopt provisions to measure delay start mode separately or as part of the active washing mode. Instead, DOE proposed adopting the “alternate approach,” in which all low-power mode hours would be allocated to the inactive and off modes, and the low-power mode energy consumption would be measured only in the inactive and off modes, depending on which of these modes is present.
ALS, AHAM, and Whirlpool supported DOE's proposal to consider delay start mode as part of active mode. (ALS, No. 10 at p. 1; AHAM, No. 14 at p. 3; Whirlpool No. 13 at p. 2) BSH supported the proposed delay start mode definition, and agreed that this mode should be included in the test procedure. (BSH, No. 17 at p. 2) AHAM and ALS supported using the “alternate approach” for measuring power in low-power modes. AHAM opposed separately measuring delay start mode, stating that the additional complexities of the test significantly add to the testing burden without a corresponding benefit to the public interest. AHAM stated that the
de minimus
amount of energy that will be measured, 0.04 to 0.2 kWh annually per DOE's data, will not add significantly, or possibly at all, to national consumption figures. (AHAM, No. 14 at p. 6; AHAM, No. 24 at p. 3; ALS, No. 22 at p. 2)
Whirlpool commented that the LED-based technology on which DOE proposed a 60-minute delay start mode is rapidly disappearing from new product introductions. (Whirlpool No. 13 at p. 3) Whirlpool also commented that the 60-minute delay start mode test would add substantial test burden (6-7 percent), with little or no impact on overall measured energy consumption. Whirlpool believes that this would create an unacceptable test burden for manufacturers and strongly urged the Department to drop this proposal. (Whirlpool No. 13 at p. 4)
NEEA agreed that delay start mode is an active mode, but stated that the measurement of energy consumption in this mode should be folded into the measurements during the active washing mode. (NEEA, No. 12 at p. 5; NEEA, No. 26 at pp. 2, 7) NEEA indicated that it would support the proposed methodology of setting a 5-hour delay and measuring for one hour if DOE continued with the proposal to measure the energy use of delay start mode separately. NEEA also stated that the warm-up period should be 10 minutes to be consistent with IEC Standard 62301 general procedures, rather than the proposed 5 minute warm-up period. (NEEA, No. 12 at p. 5) NEEA commented that DOE did not fully understand the reasons why delay start mode would be used in a
household; according to NEEA, in some households the delayed start function is used to allow time for stain-removal compounds to work before the wash cycle starts. The delayed start time is based on the stain-removal compound manufacturer's recommendation for a soak time of 30 minutes. NEEA suggested that DOE acquire consumer data regarding usage of this feature, including the average time spent in delay start mode. (NEEA, No. 12 at pp. 5-6; NEEA, No. 26 at p. 7)
BSH commented that delay start mode contributes a negligible amount of energy consumption to consumers due to low usage and low energy consumption during usage. According to BSH, measuring this energy is not a valuable use of DOE or manufacturer lab resources. (BSH, No. 17 at p. 2) However, should measurement of delay start mode be required, BSH agrees with the proposed method. (BSH, No. 17 at p. 3)
Upon consideration of the data and estimates provided in the September 2010 NOPR, the uncertainty regarding consumer usage patterns, and the additional test burden that would be required, DOE has determined that measuring the energy consumption of delay start mode separately would introduce significant test burden without a corresponding improvement in a representative measure of annual energy consumption. Therefore, this final rule adopts the “alternate approach,” in which the energy use in all low-power modes (including delay start mode) is accounted for by allocating all low-power mode hours to the inactive and off modes. Low-power mode energy consumption is then measured in the inactive and off modes, depending on which of these modes is present. Section III.B.7 provides additional information regarding the measurement of low-power mode. As a result, this final rule does not include provisions to measure delay start mode separately as part of the active washing mode.
Cycle Finished Mode
DOE proposed in the September 2010 NOPR to define cycle finished mode as an active mode that provides continuous status display following operation in the active washing mode. As with delay start mode, cycle finished mode is not a mode that may persist for an indefinite time. Operation in cycle finished mode occurs only after operation in the active washing mode. Therefore, DOE considered cycle finished mode as a short-duration function associated with active mode and proposed to define cycle finished mode as a part of active mode.
DOE noted that some clothes washers available at the time of publication of the September 2010 NOPR offered energy-consuming features other than a continuous status display in cycle finished mode. For example, certain models may periodically tumble the clothes to prevent wrinkles for up to 10 hours after the completion of the wash cycle. Some models may also use a low-power fan to circulate air around the damp clothes to prevent odors. These functions, while enabled, would use more energy than the continuous display normally associated with cycle finished mode. However, DOE research indicated that the number of residential clothes washers equipped with such features represents less than 10 percent of the residential clothes washer market. In addition, review of product literature for the clothes washers equipped with such features shows that these features are typically consumer-selected options. DOE determined that measuring the energy use from these functions would significantly increase the test cycle duration to capture a negligible contributor to annual energy consumption. Therefore, DOE did not propose to amend the test procedure to address these specific cycle finished mode functions.
DOE received numerous comments in response to the September 2010 NOPR regarding cycle finished mode. ALS, Whirlpool, and AHAM stated that cycle finished mode should be considered a part of active mode. (ALS, No. 10 at p. 1; Whirlpool, No. 13 at p. 2; AHAM, No. 14 at p. 3) Whirlpool supported DOE's proposal to exclude cycle finished mode energy consumption due to air circulation or periodic tumbling because these functions are very limited in their application, and the measurement burden would substantially outweigh the value. (Whirlpool, No. 13 at p. 2) AHAM commented that it does not support measuring cycle finished mode separately from the rest of the active mode. (AHAM, No. 14 at p. 6)
NEEA disagreed with DOE's proposed cycle finished definition. NEEA commented that the proposed cycle finished mode definition comprises only a display function, which could exclude other energy-consuming features in a cycle finished mode. (NEEA, No. 12 at p. 2) Additionally, NEEA commented that it did not understand how DOE proposed to measure energy consumption in cycle finished mode for clothes washers with energy-consuming features other than a continuous status display, such as tumbling of the drum or a fan circulating air. (NEEA, Public Meeting Transcript, No. 20 at pp. 35-36) NEEA stated that, based on information from a clothes washer tax credit program conducted in the state of Oregon, it is aware of thousands of clothes washers that include tumbling after the end of the wash cycle. (NEEA, Public Meeting Transcript, No. 20 at p.37)
To address these concerns, NEEA proposed the following alternate definition of cycle finished mode: “Cycle finished mode means the portion of the active mode between the end of the active washing mode and the beginning of the inactive mode.” (NEEA, No. 12 at p. 2; NEEA, No. 26 at p. 4) NEEA also suggested that DOE create a methodology to measure cycle finished activity, which IEC Standard 62301 is attempting to do, so that any energy consumption that occurs during that period can be measured. (NEEA, Public Meeting Transcript, No. 20 at pp. 40-41) NEEA suggested that an appropriate temperature use factor (TUF) should be applied to delayed start and cycle finished modes. (NEEA, No. 31 at p. 2)
NRDC, the American Council for an Energy Efficient Economy (ACEEE), and the Appliance Standards Awareness Project (ASAP), jointly (hereafter, the “Joint Commenters”) suggested that DOE expand the definition of cycle finished mode to include any energy-consuming features following operation in the active washing mode. The Joint Commenters stated that to avoid additional testing burden for clothes washers that only have a continuous display in cycle finished mode, DOE could specify a separate test procedure and a different number of annual hours to cycle finished mode for clothes washers with additional energy-consuming features. Additionally, this comment noted that if these features are not captured in the test procedure, manufacturers will have no incentive to reduce their energy consumption in cycle finished mode while providing the additional functionality. (Joint Commenters, No. 16 at p. 4) The Joint Commenters and the California Utilities also noted that machines having these additional features in cycle finished mode are likely to become more available in the marketplace in the future, and therefore it is not appropriate to exclude the energy consumption from these features in the test procedure. (Joint Commenters, No. 16 at pp. 3-4; California Utilities, No. 18 at p. 2)
BSH commented that DOE needs to define cycle finished mode more clearly. According to BSH, the proposed definition attempts to differentiate the
end-of-cycle signal from a “left-on mode.” BSH stated that it is unclear what is considered cycle finished mode and what is inactive mode, and that more clarity and detail is needed in the definition (BSH, No. 17 at p. 2)
In the August 2011 SNOPR, DOE presented results from additional laboratory testing to quantify the energy consumption in cycle finished mode. The test results indicated that including specific measurement of a cycle finished feature that incorporates intermittent tumbling and air circulation would not significantly impact the total annual energy consumption. Furthermore, measuring the energy use over the entire duration of the cycle finished mode could increase the test duration by up to 10 hours, depending on the maximum duration of the cycle finished mode provided on the clothes washer. Therefore, DOE proposed not to adopt provisions to measure cycle finished mode separately as part of the active washing mode.
In response to the August 2011 SNOPR, Whirlpool agreed with DOE's proposal not to adopt measurement of cycle finished mode, stating that the test burden would be substantially greater with virtually no consumer benefit. (Whirlpool, No. 27 at pp. 1-2)
NEEA disagreed with the definition of cycle finished mode and reiterated its proposal to define cycle finished mode as follows: “Cycle finished mode means the portion of active mode between the end of the active washing mode and the beginning of the inactive mode.” NEEA opposed ignoring cycle finished mode hours and energy use, and stated that the energy associated with cycle finished mode should be included as part of active mode. NEEA stated that in the worst case scenario, the energy use in cycle finished mode consumes around 20 percent of the total clothes washer machine energy, when dryer energy use is excluded. NEEA stated that cutting the cycle finished energy to one-third of the worst-case scenario would still represent 7 percent of the total machine energy consumption. NEEA stated that if energy use in cycle finished mode is considered to be insignificant, the same logic could be applied to standby and off modes, which is an argument Congress already rejected. (NEEA, No. 26 at pp. 2-7)
The Joint Commenters stated that the demonstrated potential consumption of energy in cycle finished mode warrants the testing of cycle finished mode in the test procedure. The Joint Commenters further stated that the amount of energy consumed in cycle finished mode is considerable when dryer energy is disregarded. The Joint Commenters stated that when dryer energy use is disregarded, inclusion of cycle finished mode doubles the amount of energy consumed while in low-power mode, causing the energy consumption to approach the energy consumed in active mode. The Joint Commenters believe that future clothes washers will likely incorporate more features in cycle finished mode, causing the energy consumption in that mode to increase to a more significant portion of the total per-cycle energy. The Joint Commenters support folding cycle finished mode into the existing active mode test cycle by either letting the clothes washer run through the completed cycle finished mode, or, alternatively, by terminating the test one hour after the clothes washer enters cycle finished mode. The Joint Commenters do not believe that this would significantly increase the test burden, as it would lengthen the test by one hour and would not require additional setup or test preparation. Finally, the Joint Commenters commented that the uncertainty of consumer usage patterns is an invalid argument against its inclusion in the test procedure, and that substituting reasonable estimates as proxies would suffice. (Joint Commenters, No. 23 at pp. 2-4)
The California Utilities suggested requiring separate measurements for cycle finished mode. The California Utilities stated that while they recognize that cycle finished mode represents a small percentage of energy consumption when compared to dryer energy, they believe it is a significant amount of energy and similar in magnitude to the electrical energy of the washer cycle. The California Utilities further commented in response to November 2011 SNOPR that they do not agree with DOE's assertion that cycle finished mode is activated only by the consumer, and that they possess knowledge that cycle finished mode is the default setting for certain clothes washer models, and cannot be deactivated or turned off. In addition, the California Utilities stated that there are other units that tumble more frequently than the model DOE tested. Furthermore, the California Utilities commented that the test procedure should measure all low-power modes, and that measuring all energy-consuming modes will encourage manufacturers to take efficiency into account at the beginning of their research and development efforts. (California Utilities, No. 25 at p. 2; California Utilities, No. 36 at pp. 1-2)
Upon consideration of the features that may be energized during the time period after the active washing mode and before the clothes washer enters inactive or off mode, DOE agrees that the proposed definition does not fully describe the possible functions in cycle finished mode. DOE concludes that periodic tumbling of the clothing or air circulation by means of a fan or blower constitute additional active mode functions outside the active washing mode, and thus should be included in the definition of cycle finished mode. Therefore, today's final rule adopts an expanded definition of cycle finished mode as “an active mode that provides continuous status display, intermittent tumbling, or air circulation following operation in active washing mode.”
However, upon consideration of the data and estimates provided in the September 2010 NOPR, the additional energy consumption estimates provided in the August 2011 SNOPR, the uncertainty regarding consumer usage patterns, and the additional test burden required, today's final rule adopts the “alternate approach” to account for the energy use in cycle finished mode. Under this approach, all low-power mode hours are allocated to the inactive and off modes, and the low-power mode power is then measured in the inactive and off modes, depending on which of these modes is present. Section III.B.7 provides additional information regarding the measurement of low-power mode. DOE does not include provisions to measure cycle finished mode separately as part of the active washing mode.
Self-Clean Mode
In the September 2010 NOPR, DOE proposed to define self-clean mode as an active clothes washer operating mode that is (a) Dedicated to cleaning, deodorizing, or sanitizing the clothes washer by eliminating sources of odor, bacteria, mold, and mildew; (b) recommended to be run intermittently by the manufacturer; and (c) separate from clothes washing cycles. DOE considered self-clean mode as a part of the active mode because it is a function necessary for the main functions associated with washing clothes. A clothes washer with excessive bacteria, mildew, or odor cannot wash clothes effectively.
NEEA supports DOE's proposal to include self-clean mode as a part of active mode, and to include energy and water consumption in this mode in the test procedure. (NEEA, No. 12 at pp. 5, 9; NEEA, No. 26 at pp. 5-6) However, NEEA suggests the following definition of self-clean mode to clarify the proposed version: “Self-cleaning mode means an active clothes washer operating mode that is recommended by
the manufacturer to be run for the purpose of cleaning, deodorizing, or sanitizing the clothes washer by eliminating sources of odor, bacteria, mold and mildew.” (NEEA, No. 12 at p. 5; NEEA, No. 26 at pp. 6) NEEA stated that the number of self-clean annual cycles should be based on the recommendations of the manufacturer because consumers are unlikely to use these cycles in a way that is different than recommended. NEEA also strongly recommended that whatever cycle is recommended by a manufacturer for a self-cleaning function should be the one measured as the self-cleaning cycle. (NEEA, No. 12 at p. 9) NEEA also urged DOE to acquire consumer usage data on how self-clean cycles are actually used. (NEEA, No. 12 at p. 9; NEEA, No. 26 at p. 8)
The Joint Commenters support the inclusion of self-clean mode in the test procedure. The Joint Commenters stated that the definition should not be limited to machines equipped with an explicitly designated self-clean cycle, because self-cleaning may be undertaken with an appropriate cleaning compound through the use of a standard cycle available for washing clothes. (Joint Commenters, No. 16 at p. 3; Joint Commenters, No. 23 at p. 5)
The Joint Commenters also recommended that a usage factor of 12 cycles per year should not be uniformly applied to all washers, but rather should be based on the level of usage recommended by the manufacturer, converted as necessary to the appropriate number of cycles per year for the test procedure. This would provide further encouragement for manufacturers to develop approaches to sanitizing and deodorizing issues that are less energy- and water-intensive than current practices. (Joint Commenters, No. 16 at p. 3; Joint Commenters, No. 23 at p. 5)
The California Utilities commented that the proposed definition is potentially too restrictive because manufacturers may recommend intermittent self-clean cycles on machines without a dedicated self-clean feature or control. The California Utilities also commented that the calculation of self-clean cycles per year should be based on manufacturer recommendations in the product literature, rather than on a fixed number of annual self-clean cycles for all clothes washers. The California Utilities suggested that for clothes washer models that meet the definition of self-clean, but for which the manufacturer does not recommend a specific usage frequency for the self-clean cycle, the test procedure should assume the default value of 12 self-clean cycles per year. (California Utilities, No. 18 at p. 3; California Utilities, No. 25 at p. 3)
NRDC expressed concern that if a manufacturer recommends a periodic sanitizing regimen on a machine with no hardware or software dedicated to self-cleaning, these cycles would not be captured by the proposed definition. NRDC also commented that self-clean mode should be based on the manufacturer's recommendation, and not on design features. (NRDC, Public Meeting Transcript, No. 20 at pp. 47-48, 79-80)
Whirlpool commented that DOE should not include self-clean cycles in the clothes washer test procedure. Whirlpool stated that including this mode for clothes washers with such functionality, while not including it for other machines, disadvantages machines that include a self-clean cycle. According to Whirlpool, some consumer publications and manufacturers recommend running periodic cleaning cycles with baking soda or vinegar, and there is no known data on the consumer use of such practice. (Whirlpool, No. 13 at p. 2) Whirlpool proprietary data indicates that actual consumer use of a self-clean cycle is substantially less than the 12 times per year that DOE proposed, and that this data supports exclusion of self-clean energy from the test procedure. (Whirlpool, No. 13 at p. 5-6) Whirlpool also commented that if the self-clean cycle is included at the frequency of use recommended by the manufacturer, this could lead to manufacturers suggesting less frequent use. (Whirlpool, No. 13 at p. 5-6) Whirlpool estimated that the inclusion of a self-clean cycle in the test procedure would add approximately 8 percent to the overall test burden, or 8 hours, and that the amount of energy and water used by the average Whirlpool clothes washer during such cycles per year would be less than 1 percent of annual energy consumption and 3 percent of annual water consumption. Whirlpool believes that the added test burden outweighs the added benefit of including self-clean cycles in the test procedure. (Whirlpool, No. 13 at pp. 2, 6) However, Whirlpool agreed that if self-clean mode were included in the test procedure, it would be a part of active mode. (Whirlpool, No. 13 at p. 2).
AHAM opposes the inclusion of self-clean mode in the test procedure, but stated that if DOE decides to include it, AHAM agrees with the proposed definition as the best way to ensure measurement of all machines with a self-clean feature. (AHAM, No. 14 at p. 4) AHAM also notes that self-clean cycles have become necessary in large part due to the increasingly stringent energy and water consumption standards which, in practice, require many machines to use cold water instead of hot or warm water, and to use less water. (AHAM, No. 14 at p. 10) AHAM commented that there is no consumer use data to show whether and/or how often consumers use self-clean cycles, and that test procedures must be representative of actual consumer use, not manufacturer recommendations. AHAM believes that DOE should not include additional energy measurements in the test procedure without consumer data to support its addition and to quantify the energy impact. (AHAM, No .14 at p. 10) AHAM also commented that DOE's proposal to include self-clean cycles unfairly disadvantages clothes washers with a self-clean feature, which may dis-incentivize the feature, the result of which would not benefit consumers. AHAM stated that it is difficult to define an approach that would not encourage test procedure circumvention. (AHAM, No. 14 at p. 11).
BSH stated that self-clean mode should include only cycles specifically designed and provided for such activities. According to BSH, consumers are less likely to perform such activities without a dedicated program or option. (BSH, No 17 at p. 2) BSH commented that should the self-clean cycle be included, the number of cycles per year should be specified to match the manufacturer's suggestion to the customer. Otherwise, the motivation to reduce the need for such cycles is not present and manufacturers may not pursue innovations to reduce this need. (BSH, No. 17 at p. 2) However, BSH commented that it does not see the value to the consumer or DOE in assessing self-clean mode energy consumption, and suggests that these hours be removed or allocated to the active washing mode according to the self-cleaning cycles per year specified by the manufacturer. (BSH, No. 17 at p. 3) BSH stated that including the self-cleaning cycles will not significantly contribute to the annual energy consumption of residential washing machines. BSH suggests that instead of testing the self-clean cycle, the total number of annual active-mode cycles per year in the current energy calculations could be increased by a small value. (BSH, No. 17 at p. 2) Additionally, BSH does not agree that self-clean modes are necessary for the main functions associated with clothes washing, otherwise all clothes washers
would need such cycles. (BSH, No. 17 at p. 2).
ALS opposes DOE's proposed definition of self-clean mode as being part of active mode, and commented that DOE should not propose an energy test measurement without consumer use data to support it. (ALS, No. 10 at p. 1) ALS stated that self-clean cycles should not be added to the test procedure until there is reliable consumer data and an understanding of the energy consumed in self-clean cycles. ALS also stated that the test burden on manufacturers outweighs the public benefit at this time. (ALS, No. 10 at p. 3).
China does not support DOE's proposal to include self-clean mode in the test procedure. China commented that self-clean functions reduce bacteria and mildew that may harm the user, and thus are significant for health reasons. China stated that if self-clean mode were included in the test procedure, manufacturers might reduce the temperature or shorten the cycle time of a self-clean cycle to improve energy performance, which would be detrimental to consumers. China also expressed concern that this standard would lead to differences in energy consumption between units with and without self-cleaning functions, and stated that such distinct types of clothes washers should not be subject to the same energy standard. China noted that, as DOE proposed, self-clean mode represents a very short use time of only 16 hours per year, or 1.3 hours per month. Because of this minimal use time, China recommends not including the energy and water consumption during a self-clean cycle in the test procedure. (China, No. 19 at p. 3).
GE commented that it does not disagree with DOE's assumption of 12 self-clean cycles per year, but stated that consumers would be dissatisfied to have to use this feature monthly. GE expects that manufacturers will be working to reduce the required number of self-clean cycles per year. GE suggested that DOE use the manufacturer's recommendation for the number of self-clean cycles. (GE, Public Meeting Transcript, No. 20 at pp. 77-78, 107).
In reviewing these comments, DOE recognizes a lack of consensus regarding whether a self-clean mode is uniquely associated with a dedicated feature provided on a clothes washer, or whether self-clean mode may describe a consumer-initiated function associated with a normal wash cycle. DOE recognizes that a cleaning or deodorizing action in the clothes container may be achieved in either case, but that it is not clear whether such a cycle would be differentiable from a normal wash cycle in the event that a self-clean feature is not provided. In addition, DOE lacks information on the consumer usage of self-clean features or typical cycles run solely for self-clean purposes, including whether consumer usage reflects manufacturer recommendations. In light of this uncertainty, and considering that the annual energy use associated with self-clean mode would be relatively small, DOE has determined for today's final rule that self-clean mode should not be addressed in the amended test procedure. Therefore, DOE is not adopting a definition for a self-clean cycle, and is not adding any provisions to the test procedure for measuring self-clean energy and water consumption. In addition, today's final rule adds a clarifying statement that the energy test cycle shall not include any cycle, if available, that is dedicated for cleaning, deodorizing, or sanitizing the clothes washer, and is separate from clothes washing cycles.
Standby Mode
In the September 2010 NOPR, DOE proposed to define standby mode as any mode in which the clothes washer is connected to a main power source and offers one or more of the following user-oriented or protective functions, which may persist for an indefinite time: (a) To facilitate the activation of other modes (including activation or deactivation of active mode) by remote switch (including remote control), internal sensor, or timer; (b) continuous functions, including information or status displays (including clocks) and sensor-based functions.
DOE proposed an additional clarification that a timer should be considered a continuous clock function (which may be associated with a display) that provides regular scheduled tasks (
e.g.,
switching) and that operates on a continuous basis. This proposed definition was developed based on the definition provided in IEC Standard 62301 FDIS.
As proposed, the definition of standby mode allowed for multiple modes to be considered a standby mode. DOE had identified only one mode that would be considered a standby mode under the proposed definition. DOE proposed to define “inactive mode” as a standby mode that facilitates the activation of active mode by remote switch (including remote control), internal sensor, or timer, or that provides continuous status display. Although it identified only this one particular standby mode, DOE remained open to consideration of additional standby modes. DOE retained this definition of standby mode in the August 2011 SNOPR.
ALS supported DOE's proposal for inactive mode to be the only standby mode. ALS also stated that it is unaware of any modes for clothes washers that represent significant energy use, other than those proposed by DOE. (ALS, No. 10 at p. 1) AHAM commented that it does not support the inclusion of one-way remote control energy in the definition of standby mode. According to AHAM, standard remote controls power down products rather than powering them off, such that the product can be turned on again through use of the remote. AHAM contrasted that to one-way remote controls, which turn a product off completely, such that it cannot be turned on again through use of the remote control. AHAM stated that one-way remote controls should be included under the definition of off mode to encourage manufacturers to design products with this feature, which could result in decreased energy use. (AHAM, No. 14 at p. 5).
Whirlpool stated that the test burden for inactive mode testing is significant (approximately an 8 percent increase) with virtually no consumer benefit. (Whirlpool, No. 13 at p. 4).
DOE notes that the definition of standby mode proposed in the September 2010 NOPR states that standby mode includes user-oriented or protective functions to facilitate the activation of other modes (including activation or deactivation of active mode) by remote switch (including remote control), internal sensor, or timer. If the clothes washer is consuming energy to power an infrared sensor used to receive signals from a remote control (while not operating in the active mode), such a function would be considered part of standby mode, regardless of whether the remote is classified as “one-way” or “two-way.” However, if a “one-way” remote control powers down the clothes washer, including turning off any infrared sensors to receive signals from a remote control, the unit would transition to off mode once it is powered down, if no other standby mode functions within the clothes washer are energized. Depending on whether the unit is capable of operating in both a standby mode and off mode or just the off mode, the annual hours associated with standby and off modes would be allocated accordingly.
In today's final rule, DOE retains the definitions of standby mode and inactive mode as proposed in the September 2010 NOPR and August 2011 SNOPR. Section III.B.7 provides further details on the test method for standby
mode adopted in the revised test procedure. As described further in section III.G.1, DOE believes that by adopting the “alternate approach” for measuring standby and off mode power, this final rule will not impose significant additional test burden on manufacturers.
Off Mode
DOE proposed in the September 2010 NOPR to define “off mode” as any mode in which the clothes washer is connected to a mains power source and is not providing any standby mode or active mode function, and the mode may persist for an indefinite time. An indicator that only shows the user that the product is in the off position would be included within the proposed off mode classification. This definition was developed based on the definitions provided in IEC Standard 62301 FDIS. DOE retained this definition of off mode in the August 2011 SNOPR.
Under the definitions proposed in the September 2010 NOPR, a clothes washer equipped with a mechanical on/off switch that can disconnect power to the display and/or control components would be considered as operating in the off mode when the switch is in the “off” position, provided that no other standby or active mode functions are energized. An energized light-emitting diode (LED) or other indicator that shows the user only that the product is in the off position would be considered part of off mode under the proposed definition, provided that no other standby or active mode functions are energized.
Other than those comments addressed in the August 2011 SNOPR, DOE did not receive any additional comments on the proposed definition of off mode. Therefore, for the reasons stated above and in the August 2011 SNOPR, DOE adopts this definition for the amended clothes washer test procedure in this final rule.
Network Mode
DOE noted in the September 2010 NOPR that IEC Standard 62301 FDIS provides definitions for network mode that DOE determined were not applicable to the clothes washer test procedure. Section 3.7 of IEC Standard 62301 FDIS defines network mode as a mode category that includes “any product modes where the energy using product is connected to a mains power source and at least one network function is activated (such as reactivation via network command or network integrity communication) but where the primary function is not active.” IEC Standard 62301 FDIS also provided a note, stating that “[w]here a network function is provided, but is not active and/or not connected to a network, then this mode is not applicable. A network function could become active intermittently according to a fixed schedule or in response to a network requirement. A `network' in this context includes communication between two or more separate independently powered devices or products. A network does not include one or more controls which are dedicated to a single product. Network mode may include one or more standby functions.” DOE did not propose any amendments to include provisions for testing network mode energy consumption in clothes washers.
AHAM, ALS, BSH, and Whirlpool stated that network mode should not be included in the test procedure at this time because no products are currently available on the market with such a feature. (AHAM, No. 14 at pp. 5, 11; ALS, No. 10 at p. 3; BSH, No. 17 at pp. 3-4; Whirlpool, No. 13 at p. 2) Whirlpool, AHAM, and NRDC further commented that DOE could consider network mode by creating a “placeholder” for it in the test procedure, so that when there is sufficient volume of network-capable clothes washers in the market, this mode could be addressed. (Whirlpool, Public Meeting Transcript, No. 20 at pp. 42-43, 46; AHAM, Public Meeting Transcript, No. 20 at pp. 43-44, 109; NRDC, Public Meeting Transcript, No. 20 at pp. 109-110).
NEEA disagreed with DOE's proposal to not include provisions for network mode in the test procedure. NEEA stated that, although no clothes washers currently on the market are capable of this mode, it has communicated with microprocessor manufacturers who intend to sell the hardware that would allow such a mode. According to NEEA, informal estimates in these conversations revealed that network mode could significantly increase the energy consumption in the inactive mode. NEEA suggested that DOE define and allow for measuring the energy use of network mode, as defined in IEC Standard 62301, and recommended that DOE include network mode under the inactive mode definition. (NEEA, No. 12 at pp. 2, 4, 10; NEEA Public Meeting Transcript, No. 20 at pp. 38-41, 45-46; NEEA, No. 26 at p. 4) NEEA supports including the definitions and methodology for network mode energy from IEC Standard 62301 (Second Edition). NEEA also commented that if DOE chooses to incorporate a network mode definition different from that in IEC Standard 62301, there could be inconsistencies when the test method from IEC Standard 62301 is applied using DOE's mode definitions. (NEEA, Public Meeting Transcript, No. 20 at pp. 22-24; NEEA, No. 26 at p. 9).
The Joint Commenters stated that clothes washers with a network mode may become common by 2015 when the new standards take effect, and multiple manufacturers have indicated their plans to introduce these features. Therefore, the Joint Commenters believe it is important for the test procedure to capture at a minimum the standby energy consumption associated with a network mode. The Joint Commenters further stated that network mode could require power consumption of 2-5 Watts, corresponding to 18-44 kWh per year. According to the Joint Commenters, if network mode is not captured by the test procedures, manufacturers will have no incentive to employ lower-power technologies for this feature. (Joint Commenters, No. 16 at pp. 1-2) The Joint Commenters and the California Utilities stated that, due to the lack of sufficient data associated with development of a test method for network mode, DOE should develop a sufficiently broad definition for inactive or standby mode to ensure that the standby test method would capture any energy consumption associated with network functionality, regardless of whether the product is connected to a network. (Joint Commenters, No. 16 at p. 2; California Utilities, No. 18 at pp. 1-2; California Utilities, No. 25 at p. 2).
NRDC commented that the AHAM-ACEEE Agreement on Minimum Federal Efficiency Standards, Smart Appliances, Federal Incentives and Related Matters for Specified Appliances
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includes an explicit commitment to recognize network functionality for major appliances in the ENERGY STAR context, so the test procedure should be prepared to assess whatever energy consumption is associated with that functionality. (NRDC, Public Meeting Transcript, No. 20 at pp. 41-42) The California Utilities further commented that DOE should include the definition of network mode to harmonize with the IEC Standard, and that it should act swiftly to issue an amendment to include a test method for network mode when it becomes aware of clothes washer models with this feature in the marketplace. The California Utilities expect network mode to become a regular feature in the future. The California Utilities stated that if DOE cannot develop a test procedure in this
rulemaking for products connected to networks, DOE should amend the test procedure as soon as it becomes aware of commercially available clothes washer models with this feature. (California Utilities, No. 18 at pp. 1-2; California Utilities, No. 25 at pp. 1-2).
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The AHAM-ACEEE Agreement on Minimum Federal Efficiency Standards, Smart Appliances, Federal Incentives and Related Matters for Specified Appliances is available at DOE Docket No. EERE-2010-BT-TP-0021, Comment No. 2.
DOE interprets the network mode provisions in IEC Standard 62301 (Second Edition) to be a forward-thinking attempt by the IEC to anticipate and/or promote technological change by industry. DOE is unaware, however, of any clothes washers currently on the market with network mode capabilities as of the date of today's final rule. Consequently, DOE can not thoroughly evaluate these network mode provisions, as would be required to justify their incorporation into DOE's test procedures at this time. DOE notes that although an individual appliance may consume some small amount of power in network mode, the potential exists for energy-related benefits that more than offset this additional power consumption if the appliance can be controlled by the “smart grid” to consume power during non-peak periods. Although DOE is supportive of efforts to develop smart-grid and other network-enabled technologies in clothes washers, today's final rule does not incorporate the network mode provisions due to the lack of available data that would be required to justify their inclusion.
Disconnected Mode
DOE noted in the September 2010 NOPR that section 3.9 of IEC Standard 62301 FDIS provided a definition of “disconnected mode,” which is “the state where all connections to mains power sources of the energy using product are removed or interrupted.” IEC Standard 62301 FDIS also added a note that common terms such as “unplugged” or “cut off from mains” also describe this mode, and that this mode is not part of the low-power mode category. Since there would be no energy use in a disconnected mode, DOE did not propose a definition or testing methods for such a mode.
AHAM agreed with DOE's proposal to not include test procedures for disconnected mode, because there would be no energy use in this mode. (AHAM, No. 14 at p. 5).
For the reasons stated in the September 2010 NOPR, DOE is not adopting a definition or testing methods for disconnected mode in this final rule.
3. Power Stabilization Criteria and Measurement Methods
In the September 2010 NOPR, DOE proposed to require measurement of standby mode and off mode power using section 5, paragraph 5.3 of the First Edition, clarified by requiring the product to stabilize for at least 30 minutes, and using a measurement period of not less than 10 minutes for cycle finished mode, inactive mode, and off mode. For instances where the power varies over a cycle, as described in section 5, paragraph 5.3.2 of the First Edition, DOE proposed to require the use of the average power approach in section 5, paragraph 5.3.2(a).
The Second Edition contains more detailed techniques for evaluating the stability of the power and measuring the power consumption of loads with different stability characteristics. In the Second Edition, the user is given a choice of measurement procedures, including a sampling method, average reading method, and direct meter reading method. In the August 2011 SNOPR, DOE evaluated these new methods in terms of test burden and improvement in results as compared to the methods provided in the First Edition. Based on this analysis, DOE proposed using the sampling method for all measurements of standby mode and off mode power. The following sections provide additional details on each power stability scenario.
Stable, Non-Cyclic Power
In the September 2010 NOPR, DOE proposed measuring stable, non-cyclic power by allowing the product to stabilize for at least 30 minutes, followed by a measurement period of at least 10 minutes using the test procedure specified in section 5, paragraph 5.3.1 of the First Edition. This method defines stable power as varying less than 5 percent over a 5 minute period. If the load is considered stable, the power can be recorded directly from the power-measuring instrument at the end of the measurement period.
In the August 2011 SNOPR, DOE proposed measuring stable, non-cyclic power by allowing the product sufficient time to reach its low power state and then following the test procedure for the sampling method specified in section 5, paragraph 5.3.2 of the Second Edition. The sampling method requires measuring and recording the power over a period of at least 15 minutes. Data from the first third of the measurement period are discarded, and stability is evaluated by a linear regression through all power readings in the second two-thirds of the data. If the slope of the linear regression satisfies the stability criterion, power consumption is calculated as the average of the power readings during the second two-thirds of the measurement period. If the slope of the linear regression does not satisfy the stability criterion, the total period is continuously extended—up to a maximum of 3 hours—until the stability criterion is satisfied for the second two-thirds of the data taken over the total period.
In response to the August 2011 SNOPR, NEEA supports DOE's proposal to require the use of the sampling method for measuring power consumption in the inactive and off modes. (NEEA, No. 26 at p. 2).
For the reasons stated in the August 2011 SNOPR, DOE specifies the use of the sampling method in section 5, paragraph 5.3.2 of the Second Edition for all measurements of standby and off mode power, including stable, non-cyclic power.
Unstable (Varying), Non-Cyclic Power
In the September 2010 NOPR, DOE proposed measuring unstable (varying), non-cyclic power by allowing the product to stabilize for at least 30 minutes, followed by a measurement period of at least 10 minutes using the average power approach described in section 5, paragraph 5.3.2(a) of the First Edition. The average power approach requires using an instrument that can measure the true average power over a period of at least 5 minutes (which DOE proposed to extend to a minimum of 10 minutes). The average power can be recorded directly from the power-measuring instrument at the end of the measurement period.
In the August 2011 SNOPR, DOE proposed measuring unstable (varying), non-cyclic power by allowing the product sufficient time to reach its low power state and then following the test procedure for the sampling method specified in section 5, paragraph 5.3.2 of the Second Edition. Using the sampling method, for modes that are known to be non-cyclic and unstable (varying), the test period must be long enough so that the cumulative average of all data points taken during the second two thirds of the total period fall within a band of ±0.2%.
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When testing such modes, the total period must be at least 60 minutes.
6
DOE interprets this provision as follows: The cumulative average is the mean of all data points up to and including the most recent data point. Each data point collected has a cumulative average associated with it, and the variation of those averages must remain within the given band.
For the reasons stated in the August 2011 SNOPR, DOE specifies the use of the sampling method in section 5, paragraph 5.3.2 of the Second Edition for all measurements of standby and off mode power, including unstable (varying), non-cyclic power.
Cyclic Power
In the September 2010 NOPR, DOE proposed measuring cyclic power by allowing the product to stabilize for at least 30 minutes, followed by a measurement period of at least 10 minutes using the average power approach described in section 5, paragraph 5.3.2(a) of the First Edition. The average power approach requires using an instrument that can measure the true average power over a period of at least 5 minutes (which DOE proposed to extend to a minimum of 10 minutes). The average power can be recorded directly from the power-measuring instrument at the end of the measurement period. For cyclic power, section 5.3.2(a) specifies that the test period shall be one or more complete cycles to get a representative average value.
In response to the September 2010 NOPR, NEEA commented that DOE should refer to the relevant sections of IEC Standard 62301 rather than try to simplify the language in section 3.11 of appendix J2, which could be potentially misleading or confusing. NEEA described a potential conflict between the language in DOE's proposed Section 3.11 of appendix J2 and that in the referenced IEC Standard 62301 test procedure: In the case of cycle finished mode, which often may involve more than just a display, cyclic power consumption may persist for a limited duration, which would require using the “sampling approach” for power measurement rather than the “average power approach” as proposed in section 3.11.2 of appendix J2. (NEEA, No. 12 at pp. 3-4) NEEA also stated that IEC Standard 62301 CDV specifications for a longer 30-minute stabilization period are superior to the shorter 10-minute period specified in the FDIS version. In addition, NEEA believes that if cyclic power changes are discovered during the stabilization period, the power measurement period should extend for at least four cycles or one hour, whichever is longer, noting that the sampling method in Section 5.3.1 of the IEC Standard 62301 FDIS calls for measurement over a minimum of four cycles in such circumstances. (NEEA, No.12 at p. 6).
In the August 2011 SNOPR, DOE proposed measuring cyclic power by allowing the product sufficient time to reach its low power state and then following the test procedure for the sampling method specified in section 5, paragraph 5.3.2 of the Second Edition. For cyclic power modes, the sampling method requires a measurement period of at least four complete cycles (for a total of at least 40 minutes), divided into two comparison periods. Stability is established by dividing the difference in average power measured in each comparison period by the time difference of the mid-point of each comparison period. This “slope” must satisfy the specified stability criterion. If the appropriate stability criterion is not satisfied, additional cycles are added to each comparison period until stability is achieved. Once stability has been achieved, the power is calculated as the average of all readings from both comparison periods.
As described in the August 2011 SNOPR, DOE believes that the methodology for measuring cyclic power in the Second Edition produces an improved measurement over the methodology from the First Edition.
DOE received no comments on this issue in response to the proposal in the August 2011 SNOPR. Therefore, for the reasons specified in the August 2011 SNOPR, DOE specifies the use of the sampling method in section 5, paragraph 5.3.2 of the Second Edition for all measurements of standby and off mode power, including cyclic power.
4. Use of Default Settings
In the September 2010 NOPR, DOE proposed that the clothes washer be installed according to the manufacturer's instructions, but did not propose additional provisions to require the use of default settings for testing standby energy consumption because it did not have information regarding the likelihood that consumers will alter the default display settings.
In the August 2011 SNOPR, DOE proposed incorporating by reference the installation instructions in section 5, paragraph 5.2 of the Second Edition. The Second Edition adds certain clarifications to the installation and setup procedures in section 5, paragraph 5.2 of the First Edition. The First Edition required that the product be installed in accordance with the manufacturer's instructions, except if those instructions conflict with the requirements of the standard, and that if no instructions are given, the factory or default settings must be used. The Second Edition adds provisions regarding products equipped with battery recharging circuits, as well as instructions for testing each relevant configuration option identified in the product's instructions for use. DOE is not aware of any clothes washers with a battery recharging circuit. DOE agreed with commenters that testing a clothes washer for standby mode energy use at the default setting, or as-shipped if a default setting is not indicated, would ensure consistency of results from test to test and among test laboratories.
NEEA supported DOE's proposal to disregard the portions of the installation instructions in section 5, paragraph 5.2 of IEC Standard 62301 that are not appropriate for the clothes washer test procedure;
i.e.,
those pertaining to batteries and the determination, classification, and testing of relevant modes. (NEEA, No. 26 at p. 2).
For the reasons stated in the August 2011 SNOPR, DOE adopts language in this final rule to disregard the provisions of paragraph 5.2 regarding batteries and, as described in section III.B.2, the provisions regarding the determination, classification, and testing of relevant modes. This final rule incorporates by reference, with qualification as discussed above, the installation instructions in section 5, paragraph 5.2 of the Second Edition.
5. Test Room Ambient Temperature Conditions for Standby Power Testing
DOE proposed in the September 2010 NOPR that test room ambient temperatures for standby mode and off mode testing be specified according to section 4, paragraph 4.2 of IEC Standard 62301 (First Edition). The current DOE test procedure includes a test room ambient air specification of 75 ± 5 °F, for water-heating clothes washers only. This specification is narrower than the range specified by IEC Standard 62301 of 73.4 ± 9 °F. The September 2010 NOPR proposal would require manufacturers of water-heating clothes washers to use the more stringent ambient temperature range in the current DOE test procedure if all active mode, standby mode, and off mode testing is conducted simultaneously in the same test room on multiple clothes washers. Alternatively, the temperature specifications in IEC Standard 62301 would allow a manufacturer that opts to conduct standby and off mode testing separately from active mode testing more latitude in maintaining ambient conditions. The test room ambient conditions specified in IEC Standard 62301 (Second Edition) are identical to those specified in the First Edition.
BSH and NEEA support DOE's proposals regarding test room ambient temperature range. (BSH, No. 17 at p. 3; NEEA, No. 12 at p. 6) AHAM, ALS, and Whirlpool support using 75 ± 5 °F as the test room ambient temperature. (AHAM, No. 14 at p. 7; ALS, No. 10 at p. 2; Whirlpool, No. 13 at p. 3) Whirlpool and AHAM believe that this requirement should apply to all clothes washer products, not just those that include water-heating capability, because ambient temperature
significantly impacts test procedure results and should be consistent across all machines. Whirlpool and AHAM stated that this tighter tolerance will help drive consistency, repeatability and reproducibility across machines and laboratories. (Whirlpool, No. 13 at p. 3; AHAM, No. 14 at p. 7; AHAM, Public Meeting Transcript, No. 20 at p. 58) AHAM commented further that should DOE proceed with its proposal for water-heating clothes washers only, it does not support allowing the use of the less stringent IEC range (73 ± 9 °F) because the more stringent DOE range (75 ± 5 °F) falls within the IEC range. Thus, there is no added test burden when the more stringent DOE range is used for testing standby and off modes. (AHAM, No. 14 at p. 7).
Whirlpool and AHAM commented that there appears to be some inconsistency between DOE's proposal and the proposed language from section 2.11.2 in appendix J2, as to whether DOE is proposing to allow use of the more stringent or less stringent ambient temperature range. It appears to Whirlpool and AHAM, based on the proposed language in section 2.11.2, that DOE's intent is to allow use of the less stringent IEC Standard 62301, First Edition ambient air temperature conditions of 73 ± 9 °F for measurement of standby, off, delay start, and cycle finished mode testing. (Whirlpool, No. 13 at p. 3; AHAM, No. 14 at p. 6) AHAM commented that DOE should reference IEC Standard 62301 Second Edition, FDIS version rather than the First Edition. (AHAM, No. 14 at p. 6).
After considering comments from interested parties, DOE has determined that the same ambient test room temperature requirement should apply to all clothes washer products, not just those that include water-heating capability. Because the temperature of the internal clothes washer components will be the same as the ambient room air temperature at the start of a test, maintaining the same ambient test room temperature would ensure that any heat loss from water in the machine during the test would be factored into the measured energy and water use in a consistent manner across all machines, both water-heating and non-water-heating. DOE also concurs with some commenters that the more stringent temperature range of 75 ± 5 °F will produce more accurate, repeatable, and reproducible results compared to the 73 ± 9 °F range. DOE also notes that the current test procedure requires a temperature range of 75 ± 5 °F for active mode testing. Therefore, performing standby and off mode testing at 75 ± 5 °F should not result in any additional test burden for manufacturers. For these reasons, today's final rule includes a test room ambient temperature specification of 75 ± 5 °F for both water-heating and non-water heating clothes washers. The amended test procedure does not adopt the test room ambient temperature range specified in IEC Standard 62031 (Second Edition) for standby and off mode testing.
6. Power Supply and Power Measuring Instruments
In the August 2011 SNOPR, DOE proposed to incorporate by reference the power supply and power-measuring instrument specifications in section 4, paragraphs 4.3 and 4.4 of the Second Edition. Specifically, paragraph 4.3.2 requires that the value of the harmonic content
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of the voltage supply be recorded during the test and reported. Paragraph 4.4.1 requires the crest factor and maximum current ratio (MCR) to be determined. The value of MCR determines the maximum permitted uncertainty for the power measurement. Paragraph 4.4.3 requires the instrument to be capable of measuring the average power or integrated total energy consumption over any operator-selected time interval.
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As defined in the Second Edition, harmonic content (or total harmonic content) is equivalent to total harmonic distortion (on an amplitude, not power, basis; i.e., using the square root of the squares of the RMS voltages of the harmonics in the numerator).
As described in the August 2011 SNOPR, DOE believes that the test burden associated with the additional measurements and calculations in the Second Edition is offset by the more reasonable requirements for testing equipment, while maintaining acceptable measurement accuracy. DOE also proposed in the August 2011 SNOPR for it to be acceptable to measure the total harmonic content, crest factor, and MCR before and after the actual test measurement if the power-measuring instrument is unable to perform these measurements during the actual test measurement.
AHAM, ALS, Whirlpool, and NEEA support DOE's proposed interpretation to allow measurement of the total harmonic content, crest factor, and maximum current ratio before and after the actual test measurement if the power-measuring instrument is unable to perform these measurements during the actual test measurement. (AHAM, No. 24 at p. 2; ALS, No. 22 at p. 1; NEEA, No. 26 at p. 2; Whirlpool, No. 27 at p. 1) Whirlpool added that individual manufacturers should decide whether to measure these parameters during the test, and that measuring the power parameters during the test would require some manufacturers to purchase new test equipment. Whirlpool believes that such economic burden should not be placed on manufacturers where an appropriate alternative exists. Whirlpool also commented that these test provisions should not be applicable until the effective date of appendix J2. (Whirlpool, No. 27 at p. 1).
DOE noted in the August 2011 SNOPR that performing the continuous linear regression analysis required by the sampling method in the Second Edition may require the use of data acquisition software with the capability of performing real-time data analysis. DOE requested comment on the potential test burden for a laboratory that would be required to upgrade its data acquisition system software to enable real-time data analysis capabilities.
AHAM stated that few laboratories currently have the real-time statistical analysis capabilities that DOE believed would be required to perform the continuous linear regression analysis of the stable, non-cyclic power test. AHAM added that several laboratories will need to invest both time and money to add a real-time statistical analysis capability to their data acquisition systems. AHAM further stated that updating data acquisition systems to enable real-time statistical analysis capabilities will require a significant upgrade. Whirlpool opposes the requirement to perform real-time statistical analysis because that such a requirement could require a significant capital investment by manufacturers. In addition, Whirlpool stated that the phrase “real-time statistical analysis” is vague and would require clarification if it were to be implemented. ALS stated that it has already equipped its lab to measure standby power per IEC Standard 62301 (First Edition) and understands that only a minimal software update expense would be needed to comply with the Second Edition. (AHAM, No. 24 at p. 2; ALS, No. 22 at p. 1; Whirlpool, No. 27 at p. 1).
After further testing and examination of the sampling method described in the Second Edition, DOE has determined that the analyses required by the sampling method could be performed without the need for real-time data analysis software. For example, a laboratory could acquire data for a discreet period of time and determine afterward whether the data satisfied the appropriate stability criteria. If these criteria were not satisfied, the laboratory could resume testing for a longer discrete period of time, followed by analysis of the data, and so on, until the
stability criteria are satisfied. Therefore, a manufacturer or test laboratory could conduct standby and off mode testing using the sampling method in the Second Edition without being required to upgrade its software with real-time data analysis capabilities. DOE notes, however, that having such real-time data analysis capabilities would facilitate this testing.
In today's final rule, DOE specifies the use of the power supply and power-measuring instrument specifications in section 4, paragraphs 4.3.2 and 4.4 of the Second Edition. The amended test procedure also includes notes in section 2.2.2 (supply voltage waveform) and section 2.5.3 (power meter) stating that if the power-measuring instrument used for testing is unable to measure the total harmonic content, crest factor, power factor, or maximum current ratio during the measurement period, it is acceptable to measure and record these properties immediately before and after the test measurement period.
7. Calculation of Energy Consumption in Each Mode
In the September 2010 NOPR, DOE proposed two possible approaches for measuring energy consumption in modes other than active washing mode;
i.e.,
inactive (standby) mode, off mode, delay start mode, and cycle finished mode
8
(hereafter, collectively referred to as low-power modes). For the first approach, DOE proposed allocating 295 hours per year to the active washing mode, 16 hours to self-clean mode (if applicable), 25 hours per year to delay start mode (if applicable), 15 hours per year to cycle finished mode (if applicable), and the remainder to off and/or inactive mode. Using this approach, the energy use per cycle associated with inactive, off, delay start, and cycle finished modes would be calculated by (1) calculating the product of wattage and allocated hours for all possible inactive, off, delay start and cycle finished modes; (2) summing the results; (3) dividing the sum by 1,000 to convert from Wh to kWh; and (4) dividing by the proposed 295 use cycles per year. For clothes washers with electronic controls and a mechanical on/off switch, DOE proposed to allocate half of the inactive/off mode hours each to inactive and off modes.
8
Self-clean mode, delay start mode, and cycle finished mode are considered part of the active mode.
For the second “alternate approach,” for the purpose of calculating the total energy consumed in all low-power modes, DOE proposed allocating all the hours not associated with active washing mode to the inactive and off modes and then measuring power consumption for the inactive and off modes. Using this approach, separate measurements of delay start and cycle finished mode energy consumption would not be required. This approach would allocate one hour to each active mode cycle, for a total of 295 active mode hours and 8,465 inactive/off mode hours. For clothes washers with electronic controls and a mechanical on/off switch, half of the inactive/off mode hours would be allocated each to inactive and off modes. DOE proposed using the alternate approach in the August 2011 SNOPR.
ALS commented that it supports DOE's proposal to allocate one hour to each active mode cycle. ALS also supports DOE's proposal to allocate half of the inactive/off hours each to inactive and off modes, for machines with electronic controls plus a mechanical on/off switch. (ALS, No. 10 at p. 2).
The Joint Commenters and ASAP support allocating a portion of the inactive/off hours to off mode for clothes washers with a mechanical on/off switch because of the potential energy-saving benefits that allow the consumer to reduce the energy consumption of the washer when not in use. The Joint Commenters and ASAP are concerned, however, about the lack of a specification regarding where the switch must be placed on the machine in order to receive credit. For example, a manufacturer could place a switch in a hidden location such as the back of the machine, where it would obviously not be intended for consumer use. (Joint Commenters, No. 16 at p. 4; ASAP, Public Meeting Transcript, No. 20 at p. 82) The Joint Commenters encourage DOE to specify that the switch must be placed on the front panel of the machine in order for half of the inactive/off mode hours to be allocated to off mode. (Joint Commenters, No. 16 at p. 4).
NEEA supports DOE's proposed alternate approach, with the caveat that delay start and cycle finished modes should be measured and included as part of the active wash mode. NEEA does not support DOE's proposal for using a one-hour average cycle time to determine annual active wash mode hours. NEEA stated that DOE's estimate, which was based on the behavior of a very limited sample of clothes washers, characterizes the behavior and energy use of the “average” clothes washer available in the market today, rather than measuring the actual performance of individual models. NEEA stated that the active washing mode hours should be based on the test results of the individual clothes washer model being tested. NEEA further commented that the energy use calculation could be greatly simplified if the calculation simply involved “active mode” and “inactive mode hours,” as measured for each model tested. Furthermore, NEEA does not support DOE's proposal to create a new class of modes called “low-power modes,” and stated that delay start and cycle finished modes should only be considered part of active mode and/or active washing mode. (NEEA, No. 12 at pp. 6-7; NEEA, No. 26 at pp. 2, 4, 6).
Whirlpool commented that it does not support DOE's proposal to split the non-active mode hours in half between inactive and off modes for washers with a mechanical or hard on/off switch. Whirlpool stated that such a device would add little benefit compared to its additional cost. Further, consumers are unlikely to utilize such a device unless it automatically defaults to the “off” mode at the end of each cycle (requiring the consumer to turn it to “on” for each new cycle initiated). According to Whirlpool, such an approach would be an annoyance to consumers and would cause consumers to postpone replacement purchases, thereby negating or delaying the resultant energy savings. Whirlpool stated that for any washer with a mechanical on/off switch, all of the non-active hours should be allocated to inactive mode. (Whirlpool, No. 13 at p. 4).
AHAM commented that it does not oppose using the estimate of one hour per cycle because it would be too burdensome and complicated to determine a more refined number, and there would be little corresponding benefit in accuracy. (AHAM, No. 14 at p. 7) AHAM also commented that it does not oppose DOE's proposal to allocate half of the inactive/off hours each to inactive and off modes for clothes washers with electronic controls plus a mechanical on/off switch. AHAM proposed that DOE add a requirement that the on/off switch must be accessible by the consumer, because a switch that is hidden such that the consumer might never find or use it should not be given this “credit.” AHAM further commented that this does not mean that DOE should specify product design by dictating where the switch should be placed on the machine. Furthermore, AHAM stated that there may be situations that warrant allocating all of the inactive/off hours to off mode; for example, there are machines that electronically turn off certain modes at the end of the active wash cycle and require the consumer to manually turn that mode back on to use it. (AHAM, No. 14 at p. 8).
DOE based its proposal to adopt an estimate of one hour per active mode wash cycle on the test data available. DOE concurs with AHAM's comment that performing additional testing to determine a more refined number would be too burdensome and complicated, with little corresponding benefit in overall accuracy. Basing the active washing mode hours on test results of the individual clothes washer model being tested would not be feasible because the energy test cycle includes numerous different wash cycles, each with a different cycle time. Calculating the average cycle time across all cycles for an individual washer would increase test burden with little or no corresponding increase in the accuracy of the results. Therefore, today's final rule allocates one hour to each active mode cycle, with 8,465 hours allocated to all other non-active mode cycles.
As described previously in section III.B.2, DOE adopts the “alternate approach,” in today's final rule, in which all low-power modes are allocated to the inactive and off modes, depending on which of these modes is present. The aggregate power of the low-power modes is represented by a single energy metric called “combined low-power mode.” DOE's analysis indicates that the assumption that the power in each low-power mode is similar, which DOE set forth in the September 2010 NOPR, remains valid, and that measuring the power of each mode separately would introduce significant test burden without a corresponding improvement in a representative measure of annual energy use.
Regarding the allocation of hours between inactive mode and off mode, the proposed definition of off mode as applied to residential clothes washers will primarily apply to units with mechanical controls. The proposed definition of inactive mode will primarily apply to units with electronic controls, in which reactivation of the clothes washer occurs through a pushbutton sensor, touch sensor, or other similar device that consumes power. DOE is not aware of any clothes washers on the market with electronic controls and an additional mechanical on/off switch. However, DOE believes that the test procedure should accommodate this option because of the potential energy-saving benefits provided by a mechanical on/off switch. DOE further notes that for units with all hours allocated to either inactive or off mode, the power measurement procedure and calculation of low-power mode energy consumption are identical. For these reasons, DOE adopts the proposal in the August 2011 SNOPR, which allocates 8,465 hours to off mode if no inactive mode is possible, 8,465 hours to inactive mode if no off mode is possible, and 4,232.5 hours to both inactive mode and off mode if both modes are possible.
DOE believes that manufacturers would be unlikely to install a mechanical on/off switch in an inaccessible location, because such a device would add little consumer benefit compared to its additional cost to the manufacturer. Therefore, today's final rule does address the location for an on/off switch.
8. Integrated Modified Energy Factor (IMEF)
The DOE test procedure for clothes washers currently provides a calculation for modified energy factor (MEF), which equals the clothes container capacity in cubic feet divided by the sum, expressed in kWh, of (1) the total weighted per-cycle hot water energy consumption, (2) the total weighted per-cycle machine electrical energy consumption, and (3) the per-cycle energy consumption for removing the remaining moisture from a test load. (See section 4.4 of appendix J1). The current Federal energy conservation standards for clothes washers are expressed in MEF. (10 CFR 430.32(g)(3))
As described previously in section I.C, EISA 2007 amended EPCA to require DOE to amend its test procedures for all covered products to integrate measures of standby mode and off mode energy consumption into the overall energy efficiency, energy consumption, or other energy descriptor unless the current test procedure already incorporates standby and off mode energy consumption, or such integration is technically infeasible.
In the September 2010 NOPR, DOE proposed to establish an “integrated modified energy factor” (IMEF) for residential clothes washers. DOE proposed to calculate IMEF as the clothes container capacity in cubic feet divided by the sum, expressed in kWh, of:
• The total weighted per-cycle hot water energy consumption;
• The total weighted per-cycle machine electrical energy consumption;
• The per-cycle energy consumption for removing moisture from a test load;
• The per-cycle standby, off, delay start, and cycle finished mode energy consumption; and
• The per-cycle self-clean mode energy consumption, as applicable.
In the August 2011 SNOPR, DOE proposed not to allocate the hours for delay start and cycle finished modes to the inactive and off modes, and not require separate measurements for delay start and cycle finished mode energy consumption. Therefore, DOE modified the proposed IMEF calculation by incorporating per-cycle combined low-power mode energy consumption instead of separate measurements of per-cycle standby, off, delay start and cycle finished mode energy consumption.
NEEA and the California Utilities support the IMEF calculation proposed in the September 2010 NOPR. (NEEA, No. 12 at p. 8; California Utilities, No. 18 at p. 2) The California Utilities further commented that although the low-power modes represent a relatively small portion of annual energy and water use, they should be measured in the test procedure because these loads will become an increasingly significant portion of overall energy use as clothes washers and other appliances make efficiency gains in their primary active mode. (California Utilities, No. 18 at p. 2).
ALS opposes the IMEF calculation proposed in the September 2010 NOPR, which separates out per-cycle standby, off, delay start, and cycle finished mode energy consumption. ALS noted that there is little public benefit to including these modes, and that DOE has no reliable consumer use data on which to base the calculations. ALS stated there is no need for a new IMEF metric. (ALS, No. 10 at p. 2).
AHAM also objected to the new IMEF measure of energy consumption due to the significant time, resource, and cost impacts associated with it. AHAM also stated that the added test burden provides no corresponding public benefit. (AHAM, No. 14 at p. 8).
NRDC questioned DOE's decision to retain a metric based on a per-cycle measure rather than an annual metric, such as for dishwashers. (NRDC, Public Meeting Transcript, No. 20 at pp. 91-92).
DOE determined in the September 2010 NOPR that it is technically feasible to integrate standby mode and off mode energy consumption into the overall energy consumption metric for clothes washers, which for the current energy conservation standards is based on the per-cycle MEF.
The current test procedure does not provide an additional energy descriptor for annual energy consumption. Any new descriptor for annual energy consumption would be based on the same per-cycle energy use measurements from which MEF or IMEF is calculated, multiplied by the number of annual use cycles; therefore, an annual energy use metric incorporating standby and off mode energy use would
not be inherently more accurate or representative than MEF or IMEF. The analogous change from a per-cycle metric to annual energy use for the energy conservation standards for dishwashers was required by Congress in the provisions of EISA 2007.
As described in section III.B.2.d, this final rule does not adopt a definition for a self-clean cycle and is not adding any provisions to the test procedure for measuring the energy and water consumption of a self-clean cycle. Today's final rule also implements the alternate approach for measuring energy consumption in low-power modes. Therefore, today's final rule calculates IMEF as the clothes container capacity in cubic feet divided by the sum, expressed in kWh, of:
• The total weighted per-cycle hot water energy consumption;
• The total weighted per-cycle machine electrical energy consumption;
• The per-cycle energy consumption for removing moisture from a test load; and
• The per-cycle combined low-power mode energy consumption.
C. Active Mode Test Procedure Provisions
1. Integrated Water Consumption Factor (IWF)
The existing calculation of water factor (WF) in the appendix J1 test procedure accounts only for the water consumed during the cold wash/cold rinse cycle. Hot water consumption is measured for all wash cycles, including warm, hot, and extra-hot washes, but it is used only to determine the energy needed to heat the water. If the cold wash water consumption is set disproportionately low, while more water is used at higher temperatures, the WF metric may not accurately reflect the average water consumption of the machine.
In the September 2010 NOPR, DOE proposed a new water consumption metric, integrated water consumption factor (IWF). This proposed metric would account for both the hot and cold water consumption of each test cycle, including any steam or self-clean cycles. As proposed, IWF would equal the sum of the total weighted per-cycle water consumption for all wash cycles and the per-cycle self-clean water consumption, divided by the clothes container volume. As proposed, the total weighted per-cycle water consumption for all wash cycles would be calculated as the TUF-weighted sum of the total per-cycle water consumption for each test cycle.
In the August 2011 SNOPR, DOE proposed a correction to the calculation for per-cycle self-clean water consumption. The proposed calculations in the newly-proposed sections 4.1.8 (per-cycle self-clean hot water energy consumption) and 4.2.14 (total per-cycle self-clean water consumption) did not contain the numeric multipliers required to apportion the total annual self-clean water consumption over the 295 representative average number of clothes washer cycles in a year. The August 2011 SNOPR proposal adjusted the calculations in section 4.1.8 and 4.2.14 by including a multiplier of 12/295, where 12 represents the average number of clothes washer self-clean cycles in a year, and 295 represents the average number of clothes washer cycles in a year.
ALS, the Joint Commenters, and NEEA expressed support for the proposal to measure water consumption for all active mode energy test cycles as part of the IWF metric. NEEA also supported DOE's proposed use of TUFs and load usage factors to derive the active mode water consumption. (ALS, No. 10 at p. 4; Joint Commenters, No. 16 at p. 8; Joint Commenters, No. 23 at p. 5; NEEA, No. 12 at p. 13) AHAM, the California Utilities, and Whirlpool specifically stated support for the inclusion in an IWF metric of hot and cold water measurements from all cycles tested. AHAM and the Joint Commenters noted that those values are already measured as part of the test procedure, and thus would not add to test burden. NEEA similarly commented that the proposed methodology for IWF would not add significant new test burden on manufacturers. Whirlpool stated that the proposal to include all water usage would prevent manufacturers from varying the amount of rinse water used at different temperatures, and that this would justify any additional test burden. (AHAM, No. 14 at p. 15; California Utilities, No. 18 at p. 5; Joint Commenters, No. 16 at p. 8; NEEA, No. 12 at p. 13; Whirlpool, No. 13 at p. 13) BSH stated that if the standards are adjusted appropriately, cold water consumption from all tests can be used in calculations. (BSH, No. 17 at p. 4) NRDC agreed with the IWF in concept. (NRDC, Public Meeting Transcript, No. 20 at pp. 182-183) The California Utilities and NEEA support the inclusion of water use from self-clean cycles in the IWF measurement. (California Utilities, No. 18 at p. 5; NEEA, No. 12 at p. 13) The Joint Commenters stated that DOE's proposal would provide a more representative depiction of water consumption. (Joint Commenters, No. 16 at p. 8).
AHAM, ALS, and Whirlpool do not support including the water use in self-clean cycles in the IWF metric. AHAM agrees, however, with the proposed correction to adjust the calculation using a multiplier of 12/295, if DOE determines that self-clean cycles should be included in the energy and water calculations. ALS also opposes the inclusion of water use in steam cycles in IWF. ALS stated that until DOE has a reliable understanding of the consumer usage and water consumed in self-clean and steam cycles, it should not include these in the test procedure. (AHAM, No. 14 at p. 15; AHAM, No. 24 at p. 5; ALS, No. 10 at pp. 4-5; Whirlpool, No. 13 at p. 13) According to BSH, inclusion of self-clean and steam cycles in the test procedure would lead to minimal improvement in IWF but would increase the test burden. (BSH, No. 17 at p. 3).
As described in sections III.B.2.d, III.C.2.a and III.C.2.b, DOE did not adopt provisions for measuring the water and energy consumption of self-clean cycles or steam cycles. In today's final rule, DOE includes an integrated water factor (IWF) metric that is based on the total weighted per-cycle water consumption of both hot and cold water for all wash cycles comprising the energy test cycle. Because these values are already measured as part of the test procedure, and no new test equipment would be required to measure these values, manufacturer test burden would not increase. DOE believes that an IWF defined in this way provides a more representative measure of total water consumption for a clothes washer.
2. Technologies Not Covered by the Current Test Procedure
Steam Wash Cycles
DOE is aware of multiple clothes washer models currently available on the market offering steam functions via pre-set cycles, or as an optional addition to conventional wash cycles. During these cycles, steam is injected into the basket, which manufacturers claim provides enhanced cleaning and/or sterilization. The steam is produced in a generator that requires a significant amount of energy to heat and vaporize the water. The current clothes washer test procedure does not account for energy or water consumption during this type of wash cycle.
In the September 2010 NOPR, DOE proposed amending the test procedure to include additional measurement of energy and water consumption during a steam wash cycle for clothes washers offering this feature. In the proposed amendments, an additional set of steam cycle tests would be required for clothes washers that offer such a feature. The
test sections required for clothes washers without a steam wash cycle would remain unchanged.
DOE also proposed in the September 2010 NOPR to include the energy and water consumption from steam wash cycles in the final calculations for the energy and water use metrics. For clothes washers capable of steam wash cycles, the measurements of energy and water consumption from the steam wash cycle with the hottest wash temperature would be included in the overall energy and water use calculations, based on the TUF for steam wash. Table 4.1.1 (Temperature Use Factors) of appendix J1 specifies the current weighting factor applied to the consumption measurements for the different wash cycles. DOE proposed to update Table 4.1.1 to include 0.02 as the TUF of a steam wash cycle, when available. DOE assumed these cycles would decrease the use of extra-hot cycles, but would leave the use of hot, warm, and cold cycles unchanged. DOE believed that the steam wash cycles would be selected somewhat fewer times than the extra hot cycle because on some models steam is available as an option only on certain settings. DOE therefore estimated that the 0.02 TUF associated with steam washes would correspond to a 0.02 decrease in the TUFs associated with extra-hot cycles, for a steam-capable clothes washer.
The California Utilities, the Joint Commenters, and NEEA expressed qualified support for DOE's proposal to include the energy and water use of steam wash cycles in the test procedure, and raised concerns about the definition of “steam wash cycle.” The California Utilities and NEEA commented that DOE may need to refine the definition of steam wash cycle for clarity and consistency. The Joint Commenters stated that the definition of “steam wash cycle” should include not only the injection of “steam” (vaporized water) but also any superheated water injected in the form of mist or fine droplets. The Joint Commenters also stated that all energy and water use resulting from steam wash cycles should be accounted for, including any injections made after the conclusion of the final spin cycle. (California Utilities, No 18 at p. 3; Joint Commenters, No. 16 at p. 3; Joint Commenters, No. 23 at pp. 4-5; NEEA, No. 12 at p. 9; NEEA, No. 26 at pp. 7-8) NEEA suggested that DOE gather data on steam cycles to more clearly define what constitutes a steam cycle. (NEEA, No. 12 at p. 9; NEEA, No. 26 at p. 8).
AHAM, ALS, BSH, and Whirlpool oppose adding measures of the energy and water consumption of steam wash cycles to the clothes washer test procedure without sufficient data on consumer usage patterns of such cycles. (AHAM, No. 14 at p. 9; ALS, No. 10 at p. 3; BSH, No. 17 at p. 3; Whirlpool, No. 13 at p. 5) ALS, BSH, and Whirlpool also oppose the inclusion of steam wash cycles due to the added manufacturer test burden, particularly because the energy use in these cycles represents such a small amount of the total annual energy. Whirlpool commented that the test burden would increase by about 10 percent. (ALS, No. 10 at p. 3; BSH, No. 17 at p. 3; Whirlpool, No. 13 at p. 5) AHAM and Whirlpool also noted that DOE does not have data on the percentage of clothes washers on the market with a steam feature. Whirlpool estimates that this percentage is likely in the single digits. (AHAM, No. 14 at p. 9; Whirlpool, No. 13 at p. 5; Whirlpool, Public Meeting Transcript, No. 20 at pp. 102-103) BSH further opposes the inclusion of steam wash cycles in the energy and water test methods because the longevity of these features in the market has yet to be proven. (BSH, No. 17 at p. 3).
GE and LG also commented that DOE needs to clarify the definition of steam wash cycle. GE suggested modifying the definition of steam cycle as: “Steam cycle means a wash cycle in which water is heated to the point of boiling to produce steam and in which that steam is injected into the clothes container.” (GE, Public Meeting Transcript, No. 20 at p. 104; GE, No. 35 at p. 2; LG, Public Meeting Transcript, No. 20 at p. 103).
AHAM questioned whether a definition of steam wash cycle would include a required temperature to which water must be heated for steam to be generated in the cycle, a representative duration of time for which steam must be injected into the drum, and a definition of the term “injected”. AHAM stated that it would be difficult to define “steam wash cycle” in a clear, repeatable, reproducible, and uniformly applicable way. According to AHAM, without a better definition of steam wash cycle, there will be confusion among manufacturers, which will lead to confusion in the market as consumers attempt to compare products. (AHAM, No. 14 at pp. 9-10) Springboard Engineering (Springboard) requested clarification as to whether steam would be tested at the hottest temperature available in the “normal” cycle, or whether it would be tested at the hottest temperature available on any cycle, such as a sanitize cycle. Springboard also noted that some clothes washers have cycles with wash temperatures greater than 135°F and steam, and stated that it is not clear how these cycles should be tested. (Springboard, No. 11 at pp. 2-3).
DOE also received comments in response to the proposed TUF for steam wash cycles. AHAM, ALS, NEEA, and Whirlpool do not support DOE's proposed steam wash cycle TUF. AHAM stated that because it does not support the inclusion of steam wash cycles in the DOE test procedure, it also opposes the revision of the TUFs to account for steam wash cycles. AHAM also questioned the assumption that the steam wash cycle TUF affects only the extra-hot TUF. (AHAM, No. 14 at p. 12) Similarly, NEEA questioned the basis on which DOE assumed that a steam wash cycle would mostly or always be associated with a hot wash cycle. According to NEEA, some consumers use a hot or extra-hot wash to kill dust mites and other allergens, not just for heavily soiled loads, and it is not clear whether such users would select a cooler wash cycle with a steam feature to accomplish the same thing. ALS, NEEA and Whirlpool objected to DOE's assignment of a TUF for steam wash cycles without supporting data. (ALS, No. 10 at p. 4; NEEA, No. 12 at p. 9; NEEA, No. 26 at p. 8; Whirlpool, No. 13 at pp. 5, 8) Whirlpool also stated that the usage of steam wash cycles is quite limited, since they are specialized cycles designed for removal of difficult stains. (Whirlpool, No. 13 at pp. 5, 8) Springboard questioned whether there are machines on the market that have a steam wash cycle but do not have a hot wash cycle. (Springboard, No. 11 at p. 3).
DOE notes that the implementation of “steam cycles” may vary among manufacturers, and that the proposed definition may lead to inconsistent interpretations of whether a certain feature constitutes a “steam cycle” to be included in the energy test cycle. In addition, consumer usage of steam features is likely to be low. For these reasons, DOE does not adopt provisions to measure the energy and water use in steam wash cycles, and therefore is not amending the TUFs in the clothes washer test procedure to include a TUF for steam wash cycles that would occur in place of certain extra-hot wash cycles.
Self-Clean Cycles
DOE is aware that some residential clothes washers currently on the market offer a self-clean cycle. These cycles are used periodically with bleach and/or detergent—but no clothes load—to clean, deodorize, or sanitize the components that come into contact with water by preventing or eliminating the formation of mold, bacteria, and
mildew. Self-clean cycles may require higher water temperatures and greater volumes of water than a normal cycle, and therefore could potentially consume a substantial amount of energy. The current test procedure does not account for energy or water consumption attributable to self-clean cycles.
As described previously in section III.B.2.d, DOE proposed in the September 2010 NOPR to define a “self-clean mode” as a clothes washer operating mode that:
• Is dedicated to cleaning, deodorizing, or sanitizing the clothes washer by eliminating sources of odor, bacteria, mold, and mildew;
• Is recommended to be run intermittently by the manufacturer; and
• Is separate from clothes washing cycles.
As described in the September 2010 NOPR, DOE observed that manufacturers typically recommended running a self-clean cycle once a month. Some manufacturers also recommend a self-clean cycle after a defined number of clothes washing cycles. Because these self-clean cycles are not accounted for in the proposed 295 wash cycles per year, DOE proposed to integrate the energy and water consumption of self-clean cycles into the overall energy efficiency metrics, under the assumption that these cycles are typically run once per month.
DOE received comments in response to the proposal to account for energy and water consumption of self-clean cycles in the overall calculations for IMEF and IWF, which are discussed in III.B.2.d, III.B.8, and III.C.1. For the reasons presented in those sections, DOE is not adopting provisions in today's final rule to include measures of self-clean energy and water use in the clothes washer test procedure.
Adaptive Control Technologies
Adaptive control technologies can adjust parameters such as agitation intensity, number of rinses, wash time, and wash and rinse temperatures based on the size, fabric mix, and soil level of a wash load. The current test procedure accounts for adaptive fill technologies, but no other types of adaptive controls.
DOE is aware that other consumer products employ adaptive controls, and that these are addressed in their respective test procedures. For example, many dishwashers incorporate adaptive controls by means of a turbidity sensor which adjusts the number and duration of wash and rinse cycles. The dishwasher test procedure accounts for these models through the use of soiled dishware loads. (10 CFR part 430, subpart B, appendix C).
In the September 2010 NOPR, DOE noted that it was not aware of any clothes washers available on the market that incorporate adaptive controls using a turbidity sensor. If clothes washers become available that offer adaptive controls using a turbidity sensor, DOE could consider amending the clothes washer test procedure to measure energy and water consumption with a soiled wash load. However, because it was not aware of any clothes washers incorporating this technology, DOE did not propose to address adaptive controls other than adaptive fill control in the test procedure.
AHAM, BSH, NEEA, and Whirlpool supported DOE's proposal that no adaptive control provisions other than the existing adaptive fill control methodology be adopted in the clothes washer test procedure at this time. (AHAM, No. 14 at p. 11; BSH, No. 17 at p. 4; NEEA, No. 12 at p. 9; NEEA, No. 26 at pp. 8-9; Whirlpool, No. 13 at p. 6) According to BSH and Whirlpool, there are currently no clothes washers on the market with soil-sensing technology. (BSH, No. 17 at p. 4; Whirlpool, No. 13 at p. 6) Whirlpool stated that if a soil-sensing clothes washer were to exist, it would require some form of sensor, which in turn would require a soiled test load to activate the sensor and properly record the energy used (analogous to the test procedure for soil-sensing dishwashers). According to Whirlpool, DOE would need to develop a uniform, consistent, repeatable, and reproducible soil load, which could take 3 or more years. (Whirlpool, No. 13 at p. 6) NEEA agreed that turbidity sensors for soil-sensing are unlikely to be found in clothes washers, but the increasing complexity of control capabilities should not be ignored. NEEA urged DOE to gather enough statistically valid data to inform a decision on whether to adopt provisions for measuring adaptive control technologies. NEEA further commented that, in the absence of information on clothes washer models with adaptive control technologies other than adaptive fill control, DOE should state how the presence of such technologies might affect the test procedure results. (NEEA, No. 12 at pp. 9-10; NEEA, No. 26 at pp. 8-9).
DOE observes that manufacturers representing approximately 65 percent of the U.S. clothes washer market stated that they are unaware of soil-sensing clothes washers currently available, supporting DOE's preliminary conclusion. For this reason, DOE is unable to evaluate any technical approaches towards adaptive control outside of adaptive fill control, nor can it develop appropriate methodology for evaluating the energy use of such features. Therefore, DOE is not adopting new provisions addressing adaptive control technologies in today's final rule.
Demand Response Technologies
Demand response technology enables an appliance to shift its activity based on interaction with the electric grid, utilities, or user programming. Appliances that can communicate with the electric grid or any other network would be considered to have a network mode as defined by IEC Standard 62301 Second Edition. As described previously in section III.B.2.g, the Second Edition defines network mode as a mode category that includes “any product modes where the energy using product is connected to a mains power source and at least one network function is activated (such as reactivation via network command or network integrity communication) but where the primary function is not active.” IEC Standard 62301 Second Edition also provides a note stating, “[w]here a network function is provided but is not active and/or not connected to a network, then this mode is not applicable. A network function could become active intermittently according to a fixed schedule or in response to a network requirement. A `network' in this context includes communication between two or more separate independently powered devices or products. A network does not include one or more controls which are dedicated to a single product. Network mode may include one or more standby functions.”
As discussed in section III.B.2.g, DOE did not propose in the September 2010 NOPR to amend the clothes washer test procedure to include any provisions for measuring energy consumption in network mode, because it was unaware of any clothes washers currently available on the market that incorporate a networking function. Additionally, DOE was unaware of any data regarding network mode in clothes washers that would enable it to determine appropriate testing procedures and mode definitions for incorporation into the test procedure.
AHAM commented that there is currently insufficient data regarding demand response features in clothes washers, but that when these features become available, DOE should address them in the test procedure. AHAM noted that it is currently working with energy and water efficiency advocates to develop a definition of “smart appliances,” including a definition of “smart” clothes washers. (AHAM, No. 14 at p. 11; AHAM, Public Meeting Transcript, No. 20 at p. 109) NEEA
doubted whether any significant fraction of laundry activities take place at peak hours, and thus it is skeptical whether households would shift their laundry schedules in response to time-of-use rates or a signal from a “smart grid” system. Even so, NEEA supported including provisions for network mode in the clothes washer test procedure for use when machines with such capabilities appear on the market. (NEEA, No. 12 at p. 10).
For the reasons stated in the September 2010 NOPR, this final rule does not incorporate provisions for clothes washers with demand response technologies. However, DOE is generally supportive of efforts to develop smart-grid and other network-enabled technologies in clothes washers. Provisions for testing power consumption in network mode could be incorporated into the test procedure through future amendments, once the appropriate data and testing methodologies become available.
3. Consumer Usage Patterns
In the September 2010 NOPR and August 2011 SNOPR, DOE proposed updating some of the consumer usage patterns contained in the test procedure. General comments on the proposals are discussed immediately below, and comments related to the specific consumer usage patterns for which DOE proposed changes are discussed in the sections that follow.
AHAM commented generally that DOE should gather or develop information on contemporary laundry practices in the United States for incorporation into the test procedure, including temperature settings, average cycles per year, special-purpose machine cycles (such as steam and self-clean), the size of a minimum laundry load, the size of an average load, and the frequency distribution of various laundry loads. (AHAM, No. 2 at p. 23; AHAM, No. 14 at pp. 1-2). EarthJustice and NRDC support this recommendation. (EarthJustice, No. 3 at p. 1; NRDC, No. 8 at p. 1) Whirlpool stated that a test procedure proposal would not be valid, meaningful, or representative of consumer practices without data to validate the underlying assumptions. Whirlpool requests that DOE accept input from manufacturers and/or initiate primary research efforts of its own to obtain updated consumer usage data, as necessary. (Whirlpool, No. 13 at p. 1).
NEEA commented that, because the revised test procedure will not be required for use before the effective date of any revised efficiency standards, DOE should take the time now to acquire enough statistically valid data to properly specify the usage patterns and calculations within the test procedure. (NEEA, No. 12 at pp. 1, 10, 16) NEEA added that DOE should consider more systematic efforts to gather field data in advance of the start of future rulemakings where test procedure changes are expected. (NEEA, No. 31 at p. 3) NEEA commented that it is currently gathering field data on the laundry habits from households participating in the Residential Building Stock Assessment, expected to be complete by mid-2013. By June 2012, field data on clothes washer and dryer energy use, the nature and size of laundry loads, washer and dryer cycle choices, and number of cycles per year will become available. (NEEA, No. 31 at p. 2).
NEEA also stated that it believes DOE is moving toward a test procedure that delivers performance results for an “average” product, rather than the specific clothes washer models being tested. NEEA believes that this approach would undermine the basic intent of the test procedure and the standards, which it believes should reasonably reflect energy and water use for each model. (NEEA, No. 12 at pp. 1-2).
DOE is aware of ongoing and future planned field studies by DOE and other parties, which are expected to provide relevant data regarding current consumer usage patterns. DOE will consider any relevant data resulting from these studies in future test procedure rulemakings.
Number of Annual Wash Cycles
In the January 2001 standards Final Rule, DOE estimated the representative number of annual wash cycles per clothes washer as 392. This number is not used in the calculations for the current energy efficiency metric, because MEF is calculated on a per-cycle basis. To include energy consumption from modes other than active washing mode in the energy efficiency metric requires an estimate of the time a typical clothes washer spends in active washing and all other non-active washing modes. The number of annual wash cycles is used to determine the time spent in the active washing mode, and also determines the remaining time to be allocated to the other possible modes.
In the September 2010 NOPR, DOE proposed 295 as the representative number of wash cycles per year, based on the 2005 Residential Energy Consumption Survey (RECS) data. DOE determined preliminarily that this was a more representative value than the results of the California Residential Appliance Saturation Survey (California RASS), which indicated 283 annual cycles, because the RECS survey was nationwide rather than limited to a single state. DOE also made a preliminary determination that the 2005 RECS value was more representative of average use than the value based on a Procter & Gamble (P&G) study, which indicated 308 annual cycles, due to the household size distributions of the data sets. Overall, however, the relatively small variation among the three estimates of annual clothes washer cycles supported DOE's conclusion that 295 cycles per year was a reasonable value to include in its clothes washer test procedure.
DOE received multiple comments in response to the proposed value of 295 annual cycles. ALS, the Joint Commenters, and Whirlpool support the proposed number of annual cycles. (ALS, No. 10 at p. 2; Joint Commenters, No. 16 at pp. 4-5; Whirlpool, No. 13 at p. 7) BSH also agrees with a value of 295 annual cycles, with the caveat that, if DOE decides to include measurement of self-clean energy and water use in the test procedure, the number of annual cycles will need to be adjusted upwards by the number of self-clean cycles per year suggested by the manufacturer in the product's user manual. (BSH, No. 17 at p. 4) ALS and AHAM questioned the validity of the 2005 RECS data, and requested that DOE work with P&G to secure more recent data. AHAM stated that P&G would be updating the clothes washer use study based on 2010 data. However, AHAM supports the proposed 295 annual cycles because it is likely that the number of cycles has decreased since the P&G data from 2005. (AHAM, No. 14 at pp. 11-12; ALS, No. 10 at pp. 2-3) However, NEEA and the National Institute of Standards and Testing (NIST) noted that the RECS and P&G data both dated from about 2005. (NEEA, Public Meeting Transcript, No. 20 at p. 112; NIST, Public Meeting Transcript, No. 20 at p. 112). Whirlpool stated that 295 cycles per year is consistent with the reduction in average household size. (Whirlpool, No. 13 at p. 7) The Joint Commenters stated that they had conducted their own analysis using the 2005 RECS data, which also resulted in an estimate of 295 annual clothes washer cycles. The Joint Commenters believe that the 2005 RECS data provide a reasonably accurate value in the absence of better data, and that the 2005 RECS data, derived from a national survey, are more representative than the California RASS data that captured usage from one state. (Joint Commenters, No. 16 at pp. 4-5).
NEEA objected to DOE's proposal for 295 annual clothes washer use cycles because NEEA believes that the 2005 RECS survey methods are flawed. According to NEEA, the relatively large bin sizes provided in the survey for the number of laundry loads per week introduces too much uncertainty regarding the average weekly number within each bin. NEEA further stated that it would not automatically discount California RASS data on the basis that the survey represents only one state. NEEA added, however, that it is not familiar enough with the California RASS data, and can not comment on the suitability of using the data to determine average annual use cycles. NEEA commented that it supports using P&G data due to P&G's longtime work in this area and the scope and detail in its survey. NEEA's interpretation of the P&G data results in an estimate of 308 annual clothes washer use cycles, which according to NEEA is similar to the approximately 310 annual cycles derived from recent data collected by the California Public Utilities Commission (CPUC). NEEA noted that while the average household size in the P&G sample is larger than those indicated by the U.S. Census and the American Housing Survey in 2007, it would be logical for households with clothes washers to be larger than average. NEEA also recommended that DOE acquire field data itself to determine annual clothes washer use cycles. (NEEA, No. 12 at pp. 10-11; NEEA, Public Meeting Transcript, No. 20 at pp. 113-114; NEEA, No. 26 at pp. 9-10).
In considering these comments, DOE notes that an independent analysis of the 2005 RECS data by the Joint Commenters resulted in essentially an identical estimate of the number of annual clothes washer cycles as DOE proposed in the September 2010 NOPR. This suggests that DOE's calculation of average annual cycles based on the weekly usage data did not introduce any systematic error in the final value of annual clothes washer cycles. DOE has also reviewed the clothes washer data recently collected in Southern California as part of SDG&E's “High Efficiency Clothes Washer Voucher Incentive Program” and PG&E's “Mass Markets Residential Program.”
9
Both programs used a combination of telephone surveys and onsite metering to determine the impact of high efficiency clothes washers on energy and water consumption. As part of the telephone surveys, program participants were asked to self-report the number of weekly wash loads. The results for these surveys, from Table 30 in the CPUC report, are shown in Table III.1 below.
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The results of these and other 2006-2008 residential energy efficiency programs run by the Investor-Owned Utilities in California are summarized in a report to the CPUC: “Residential Retrofit High Impact Measure Evaluation Report”, The Cadmus Group, Inc., Itron, Jai J. Mitchell Analytics, KEMA, PA Consulting Group, and Summit Blue Consulting, LLC, February 8, 2010.
Table III.1—Self-Reported Wash Loads From 2009 Southern California Telephone Surveys
Utility
Number of participants
Average number wash loads/week
PG&E
422
5.84
SDG&E
301
5.80
Total
723
5.82
Multiplying the average self-reported number of wash loads per week by 52 weeks per year would result in 303 annual clothes washer use cycles. This value can be compared to the results of the onsite metering studies conducted under the PG&E and SDG&E programs during the spring and early summer of 2009. These programs also recorded the actual number of wash loads per week, based on energy and water meter data, at 115 residential sites chosen to include both participants and non-participants in the utility incentive programs. The results from Table 20 in the CPUC report, disaggregated by participant status as well as clothes washer efficiency, are presented in Table III.2.
Table III.2—Measured Wash Loads From 2009 Southern California Metering Studies
Category
Efficiency
Number. of sites
Number wash loads/week
Non-Participants
Non-ENERGY STAR
24
4.77
ENERGY STAR
17
6.23
Sub-Total
41
5.38
Participants
ENERGY STAR
74
4.80
Weighted Average for all Sites
5.01
On average, subjects in the metering studies performed (5.01 loads per week) × (52 weeks per year) = 261 annual clothes washer loads, which is lower than the self-reported annual use cycles. Although in general, metering data has a higher confidence level than survey results, DOE also notes that the sample size of the onsite study was relatively small, and there was significant variation within that sample. For example, the annual use cycles for non-participants was found to range from 248 for consumers with non-ENERGY STAR clothes washers to 324 for consumers with ENERGY-STAR clothes washers. Further, the data were also collected in a limited geographical region and over only a portion of the year, and may not be fully representative of national clothes washer usage over a complete year.
For these reasons, DOE has determined that the 2005 RECS report is the most representative source of information on annual clothes washer cycles, and is adopting a value of 295 annual cycles in today's final rule.
ASAP questioned whether the proposed value of 295 annual clothes washer cycles corresponds to the number of clothes dryer cycles proposed in the amended DOE clothes dryer test procedure, accounting for the dryer usage factor. (ASAP, Public Meeting Transcript, No. 20 at p. 115) DOE adopted an amended clothes dryer test procedure in a final rule published in the
Federal Register
on January 6, 2011. (76 FR 972) In the amended test procedure, DOE revised the number of clothes dryer annual use cycles from the 416 cycles per year, previously specified by the clothes dryer test procedure, to 283 cycles. (10 CFR 430.23(d)) DOE based this revision on analysis of data from the 2005 RECS for the number of clothes washer cycles and the frequency of clothes dryer use. According to DOE's analysis of 2005 RECS data, for households with both a clothes washer and clothes dryer, the percentage of
clothes washer loads dried in a clothes dryer is 96 percent. Therefore, adopting 295 annual clothes washer use cycles in today's final rule is consistent with the amended clothes dryer test procedure.
DOE also notes that the dryer usage factor in the clothes washer test procedure adopted in today's final rule is 0.91. This value is also based on analysis of 2005 RECS data, but applies to all households with a clothes washer, as explained in more detail in section III.C.3.e of this rule.
Test Load Size Specifications
The current DOE clothes washer test procedure specifies the test load size for the active washing mode energy tests based on the clothes washer's container volume. The table specifying the test load sizes in the test procedure, Table 5.1, currently covers clothes washer container volumes only up to 3.8 ft
3
. DOE is aware that multiple clothes washers available on the market have container volumes exceeding 3.8 ft
3
.
In the September 2010 NOPR, DOE proposed extending Table 5.1 to accommodate larger clothes washer capacities, up to 6.0 cubic feet. The relationship between test load size and clothes washer volume is linear in Table 5.1 in appendix J1; DOE determined preliminarily that these values were appropriate, and that using a linear extension for larger load sizes would be valid. The proposed amendment extended the linear relationship between test load size and clothes washer container volume currently in the DOE clothes washer test procedure.
In the August 2011 SNOPR, DOE proposed some minor adjustments to the proposed extension of Table 5.1 to correct for inconsistent decimal places in the minimum and maximum load size values, which subsequently affected the calculation of some of the average load sizes. DOE proposed to amend the extension to Table 5.1 by specifying each load size value to the hundredths decimal place.
AHAM, ALS, and Whirlpool support the proposed linear extension of the test load size in Table 5.1. AHAM, ALS, EarthJustice, and NRDC agreed that DOE should extend Table 5.1 to accommodate clothes container volumes up to 6.
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